FINAL ENVIRONMENTAL IMPACT STATEMENT FOR ...

Prepared for:

United States Department of Justice Federal Bureau of Prisons

Capacity Planning and Construction Branch

July 2015

FINAL ENVIRONMENTAL IMPACT STATEMENT FOR PROPOSED UNITED STATES PENITENTIARY AND FEDERAL PRISON CAMP Letcher County, Kentucky

(This page intentionally left blank)

FINAL ENVIRONMENTAL IMPACT STATEMENT FOR PROPOSED UNITED STATES PENITENTIARY AND FEDERAL PRISON CAMP

LETCHER COUNTY, KENTUCKY

July 2015

Lead Agency: Bureau of Prisons

Title of Proposed Action: United States Penitentiary and Federal Prison Camp, Letcher County, Kentucky

Point of Contact: Mr. Issac Gaston, Site Selection Specialist, 320 First Street NW, Washington, D.C. 20534, [email protected]

Abstract

The Federal Bureau of Prisons (Bureau) has prepared this Final Environmental Impact Statement (EIS) to evaluate the environmental impacts of site acquisition and development of the a proposed United States Penitentiary (USP) and Federal Prison Camp (FPC) in Letcher County, Kentucky. The proposed action is to acquire the property and construct a new USP, FPC, ancillary facilities and access roads. The purpose of the proposed federal correctional facility in Letcher County, Kentucky, is to develop additional high-security and medium-security facilities to increase capacity for current inmate populations in the Mid-Atlantic Region based on an identified need for additional bedspace. The Bureau has determined that there is a need for additional high-security and medium- security facilities within this region to reduce the demonstrated overcrowding that compromises the mission of the Bureau. The Final EIS analyzes the direct, indirect, and cumulative impacts of the No Action Alternative, two build alternatives, Alternative 1-Payne Gap and Alternative 2-Roxana, with regard to climate, topography, geology, soils, water, biological and cultural resources, air quality, noise, land use and zoning, socioeconomics, traffic and transportation, recreation, utilities, and hazardous substances.

Final Environmental Impact Statement for USP and FPC Letcher County, Kentucky

Executive Summary ES-i July 2015

EXECUTIVE SUMMARY

INTRODUCTION The Federal Bureau of Prisons (Bureau) is proposing to construct a new United States Penitentiary (USP), Federal Prison Camp (FPC) and associated ancillary facilities in Letcher County, Kentucky. The Bureau has prepared this Final Environmental Impact Statement (EIS) to analyze the impacts associated with the construction and operation of the proposed action.

The USP is anticipated to be approximately 61,654 square meters (663,638 square foot) and will house approximately 960 inmates. The FPC is anticipated to be approximately 6,063 square meters (65,262 square foot) and house approximately 256 inmates. Ancillary buildings would include a central utility plant, firing range, outside warehouse, and staff training building. A non-lethal/lethal fence would be installed around the perimeter of the USP. Operation of the USP and FPC would employ approximately 300 full-time staff.

PURPOSE AND NEED The purpose of the proposed federal correctional facility in Letcher County, Kentucky, is to develop additional high-security and medium-security facilities to increase capacity for current inmate populations in the Mid-Atlantic Region based on an identified need for additional bedspace. The Bureau has determined that there is a need for additional high-security and medium- security facilities within this region to reduce the demonstrated overcrowding that compromises the mission of the Bureau.

PROPOSED ACTION The proposed action being evaluated in this Final EIS is the acquisition of property and the construction and operation of a federal correctional facility in Letcher County, Kentucky. The Bureau proposes to acquire approximately 800 acres (324 hectares) to construct a USP (approximately 61,654 square meters or 663,638 square foot) and FPC (approximately 6,063 square meters or 65,262 square foot) in Letcher County. Inmates housed in the USP would be high-security male inmates and those housed in the FPC would be minimum-security male inmates. The proposed facilities would house approximately 1,216 total inmates (approximately 960 within the USP and approximately 256 within the FPC). In addition to the USP and FPC, several ancillary facilities necessary for the operation of the USP and FPC would be constructed. A non-lethal/lethal fence would also be installed around the perimeter of the USP. The non-lethal/lethal fence would be placed between two parallel, chain link and razor wire fences

ALTERNATIVES CONSIDERED Three alternatives were analyzed in this Final EIS, the No Action Alternative and two build alternatives: Alternative 1-Payne Gap and Alternative 2-Roxana.

No Action Alternative

The No Action Alternative does not meet the project purpose and need; however, it represents the existing conditions and is analyzed in the EIS as a baseline for comparing the proposed action. The purpose for this comparison is to allow the federal agency to assess the effects of taking no action versus implementing the proposed action. In some cases the No Action Alternative would result in impacts to


ES-ii Executive Summary July 2015

certain resources if the proposed action is not implemented. Therefore, the assessment of the No Action Alternative is an important component of all National Environmental Policy Act (NEPA) documents.

Alternative 1-Payne Gap

Under Alternative 1, the Bureau would acquire approximately 753 acres (305 hectares) of land known as the Payne Gap site. The site is located in eastern Letcher County, approximately 7 miles northeast of Whitesburg, along the Kentucky and Virginia border (Figures 2-1 and 2-2). The Bureau would then construct and operate a USP and FPC on this site.

Alternative 1 would require extensive earthwork to prepare the site for development. Approximately 8,342,922 cubic meters (10,912,130 cubic yards) of excavation and 10,568,450 cubic meters (13,823,012 cubic yards) of fill would be required prior to the beginning of construction activities.

Alternative 2-Roxana

Under Alternative 2, the Bureau would acquire approximately 700 acres (283 hectares) of land known as the Roxana site. The site is located 7.5 miles west of Whitesburg, Kentucky (Figures 2-1 and 2-4). The Bureau would construct and operate a USP and FPC on this site.

Alternative 2 would also require extensive earthwork to prepare the site for development. Approximately 2,929,582 cubic meters (3,831,749 cubic yards) of material would need to be excavated from the site and approximately 3,282,234 cubic meters (4,293,001 cubic yards) of fill would be required to prepare the site for construction activities.

PREFERRED ALTERNATIVE Alternative 2-Roxana is the preferred alternative because it best meets the project needs and reduces impacts to the human environment.

PUBLIC INVOLVEMENT The Bureau published a Notice of Intent to prepare an EIS on July 26, 2013. The Bureau held a 30-day scoping period between July 26 and August 26, 2013. A public scoping meeting was held during this scoping period. The meeting was held August 13, 2013 to inform the public about the proposed project and to explain NEPA and the associated environmental impact analysis. A total of 453 community members attended the public meeting and a total of 320 comments were received during the 45-day public comment period. Additionally, 169 letters of support were presented at the public meeting, as well as two petitions in support of the project with a total of 124 signatures. Of the 320 comments received, 317 comments were in support of the project and 3 were not in support of the project. Issues raised in the letters that did not support the project included: socioeconomics, previous mining activities, infrastructure, and alternatives. These resources and areas of concern were analyzed in the Draft EIS.

The Notice of Availability of the Draft EIS was published in the Federal Register on February 13, 2015. A Notice of Public Meeting for the Draft EIS was published in the Federal Register on February 10, 2015. A notice of the availability of the Draft EIS and public meeting was also published in the Mountain Eagle on February 11, 2015 and the Lexington Herald on February 8, 2015. The notice announced that the Draft EIS would be available for public review and comment between February 13 and March 30, 2015. The notice identified the local libraries where hard copies of the document could be reviewed, as


Executive Summary ES-iii July 2015

well as a project website, www.fbopletchercountyeis.com, where an electronic version of the document could be reviewed.

The public meeting was held on March 12, 2015 between 5:30 p.m. and 8:00 p.m. Approximately 350 members of the public attended the public meeting. Comments received during the public comment period included 158 comments received at the public meeting; 31 comments received via mail or email; 3 petitions in support of the project with 1,001 signatures, one petition in support of the project at the Roxana site with 155 signatures, and 1,005 letters of support. Of the comments received, 1,157 of the comments (not including the petitions in support of the project) were in support of the project and 12 comments were in opposition of the project. Twenty-four of the comments in support of the project favored the Payne Gap site and 44 of the comments in support of the project favored the Roxana site.

SUMMARY OF ENVIRONMENTAL EFFECTS Table ES-1 provides a summary of the potential environmental effects from the No Action Alternative and the two build alternatives: Alternative 1-Payne Gap and Alternative 2-Roxana. Potential mitigation and site preparation costs have also been provided in this table. These mitigation measures and costs are likely to change over the course of the project, coordination with various agencies, and formal development of mitigation measures with the agencies; however, this is the best available information at the time this EIS was drafted and serves to assist in the comparison of the alternatives.

http://www.fbopletchercountyeis.com/


ES-iv Executive Summary July 2015

Table ES-1. Summary of Environmental Consequences

Resource Area Alternative 1 (Payne Gap)

Alternative 2 (Roxana) No Action Alternative

Land Use and Zoning • Compatibility issues with adjacent properties

• Compatibility issues with adjacent properties • No compatibility issues

Topography, Geology, and Soils

• Significant impacts to topography, geology, and soils

• Significant impacts to topography, geology, and soils

• No impacts to topography, geology, and soils

Socioeconomics and Environmental Justice

• No significant adverse effects • Potential beneficial economic

effects

• No significant adverse effects • Potential beneficial economic

effects

• Opportunity for beneficial economic effects would not exist

Community Facilities and Services • No adverse impacts • No adverse impacts • No impact

Transportation and Traffic

• No adverse impacts to traffic and roadways

• Minor roadway improvements would be required

• No adverse impacts to traffic; however, there would be potential adverse impacts to roadways

• Roadway improvements would be required

• No impacts to traffic

Air Quality • No significant impacts on the local or regional air quality

• No significant impacts on the local or regional air quality

• No increases in air emissions; therefore, no impacts to air quality

Noise • Short-term, temporary construction related impacts

• Short-term, temporary construction related impacts

• No construction or operation of a new facility; therefore, no impacts from increases in noise

Infrastructure and Utilities

• Significant impacts to wastewater and natural gas infrastructure

• No significant impacts

• No construction or operation of a new facility; therefore, no increase in demand on infrastructure and utilities

Cultural Resources • No adverse impacts • No adverse impacts • No construction or operation

of a new facility; therefore, no impacts to cultural resources

Water Resources

• 2.4 acres (0.97 hectares) of wetland impacts

• 10,512linear feet of stream impacts

• 2.5 acres (1.0 hectares) of wetland impacts

• 4,117 linear feet of stream impacts

• No construction or operation of a new facility; therefore, no impacts to water resources

Biological Resources

• 218 acres (88 hectares) of deforestation

• Impacts to Indiana Bat Habitat

• 93 (37 hectares) of deforestation

• Impacts to Indiana Bat Habitat

• No construction or operation of a new facility; therefore, no impacts to biological resources.

Hazardous Materials and Waste • No adverse impacts • No adverse impacts • No impacts

Known Mitigation and Associated Costs Infrastructure and Utilities $8,895,000 $15,825,000 No Cost

Threatened and Endangered Species* $1,030,000 -$1,373,400 $732,375-$1,024,355 No Mitigation

Excavation and Grading Costs $217,327,748 $141,116,447 No Cost

Notes: *Estimated costs are based on United States Fish and Wildlife Service (USFWS) cost per acre for impacts to Indiana bat and northern long-eared bat habitat for Payne Gap and Swarming P1/P2 habitat for Roxana. Cost was calculated based on total forest impacts for each site and time of year habitat is removed. Cost is based only on summer habitat impacts.


Table of Contents i July 2015

TABLE OF CONTENTS

EXECUTIVE SUMMARY ....................................................................................................................................ES-i

1.0 PURPOSE AND NEED FOR THE PROPOSED ACTION .......................................................................1-1 1.1 Background ..................................................................................................................................... 1-1 1.2 Security Levels ................................................................................................................................ 1-1 1.3 Existing Federal Prison Population .............................................................................................. 1-2 1.4 Federal Bureau of Prisons Mid-Atlantic Region ......................................................................... 1-2 1.5 Purpose and Need ........................................................................................................................... 1-3 1.6 Proposed Action .............................................................................................................................. 1-3

1.6.1 General Design Features of the United States Penitentiary and Federal Prison Camp ..................................................................................................... 1-4

1.7 Environmental Review Process ..................................................................................................... 1-4 1.7.1 National Environmental Policy Act .............................................................................. 1-4 1.7.2 Related Environmental Documents .............................................................................. 1-4 1.7.3 Agency Coordination ...................................................................................................... 1-5 1.7.4 Public Involvement ......................................................................................................... 1-5

2.0 ALTERNATIVES ..........................................................................................................................................2-1

2.1 No Action Alternative ..................................................................................................................... 2-1 2.2 Alternative Locations-Nationwide ................................................................................................ 2-2 2.3 Alternatives Development .............................................................................................................. 2-3 2.4 Alternative 1 – Payne Gap ............................................................................................................. 2-5 2.5 Alternative 2 – Roxana ................................................................................................................... 2-8 2.6 Preferred Alternative ..................................................................................................................... 2-8

3.0 DEFINITION OF RESOURCE....................................................................................................................3-1

3.1 Land Use and Zoning ..................................................................................................................... 3-1 3.2 Topography, Geology, and Soils .................................................................................................... 3-1 3.3 Socioeconomics and Environmental Justice ................................................................................. 3-1 3.4 Community Facilities and Services ............................................................................................... 3-2 3.5 Transportation and Traffic............................................................................................................ 3-3 3.6 Air Quality ...................................................................................................................................... 3-3 3.7 Noise ................................................................................................................................................. 3-5 3.8 Infrastructure and Utilities ............................................................................................................ 3-6 3.9 Cultural Resources ......................................................................................................................... 3-6 3.10 Water Resources ............................................................................................................................. 3-7

3.10.1 Clean Water Act ............................................................................................................. 3-7 3.10.2 Rivers and Harbors Act ................................................................................................. 3-8 3.10.3 Safe Drinking Water Act ............................................................................................... 3-8 3.10.4 Surface Water ................................................................................................................. 3-8 3.10.5 Wetlands and Floodplains.............................................................................................. 3-8

3.11 Biological Resources ....................................................................................................................... 3-9 3.12 Hazardous Materials and Waste ................................................................................................. 3-10

3.12.1 Hazardous Materials .................................................................................................... 3-10 3.12.2 Hazardous Waste .......................................................................................................... 3-10 3.12.3 Toxic Substances ........................................................................................................... 3-10

3.13 Cumulative Impact Analysis........................................................................................................ 3-10 3.14 Assessing Significance .................................................................................................................. 3-11


ii Table of Contents July 2015

4.0 ALTERNATIVE 1 – PAYNE GAP ..............................................................................................................4-1 4.1 Land Use and Zoning ..................................................................................................................... 4-1

4.1.1 Affected Environment .................................................................................................... 4-1 4.1.2 Environmental Consequences ....................................................................................... 4-1

4.1.2.1 Construction ..................................................................................................... 4-1 4.1.2.2 Operation .......................................................................................................... 4-1

4.1.3 No Action Alternative ..................................................................................................... 4-1 4.1.4 Mitigation ........................................................................................................................ 4-3

4.2 Topography, Geology, and Soils .................................................................................................... 4-3 4.2.1 Affected Environment .................................................................................................... 4-3 4.2.2 Environmental Consequences ....................................................................................... 4-3



4.3 Socioeconomics and Environmental Justice ................................................................................. 4-4 4.3.1 Affected Environment .................................................................................................... 4-4

4.3.1.1 Population ......................................................................................................... 4-5 4.3.1.2 Employment and Income .................................................................................. 4-5 4.3.1.3 Housing ............................................................................................................ 4-7 4.3.1.4 Environmental Justice ...................................................................................... 4-7 4.3.1.5 Protection of Children ...................................................................................... 4-8

4.3.2 Environmental Consequences ....................................................................................... 4-8 4.3.2.1 Population ......................................................................................................... 4-8 4.3.2.2 Employment and Income .................................................................................. 4-9 4.3.2.3 Housing ............................................................................................................ 4-9 4.3.2.4 Environmental Justice ...................................................................................... 4-9 4.3.2.5 Protection of Children .................................................................................... 4-10

4.3.3 No Action Alternative ................................................................................................... 4-10 4.3.4 Mitigation ...................................................................................................................... 4-10

4.4 Community Facilities and Services ............................................................................................. 4-10 4.4.1 Affected Environment .................................................................................................. 4-10

4.4.1.1 Police .............................................................................................................. 4-10 4.4.1.2 Fire ................................................................................................................. 4-10 4.4.1.3 Healthcare ....................................................................................................... 4-11 4.4.1.4 Schools ........................................................................................................... 4-11

4.4.2 Environmental Consequences ..................................................................................... 4-12 4.4.2.1 Police .............................................................................................................. 4-12 4.4.2.2 Fire ................................................................................................................. 4-12 4.4.2.3 Healthcare ....................................................................................................... 4-12 4.4.2.4 Schools ........................................................................................................... 4-12


4.5 Transportation and Traffic.......................................................................................................... 4-13 4.5.1 Affected Environment .................................................................................................. 4-13 4.5.2 Environmental Consequences ..................................................................................... 4-14

4.5.2.1 Construction ................................................................................................... 4-14 4.5.2.2 Operation ........................................................................................................ 4-14


4.6 Air Quality .................................................................................................................................... 4-15 4.6.1 Affected Environment .................................................................................................. 4-15 4.6.2 Environmental Consequences ..................................................................................... 4-16

4.6.2.1 Construction ................................................................................................... 4-16 4.6.2.2 Operations ...................................................................................................... 4-17

4.6.3 No Action Alternative ................................................................................................... 4-17


Table of Contents iii July 2015

4.6.4 Mitigation ...................................................................................................................... 4-17 4.7 Noise ............................................................................................................................................... 4-18

4.7.1 Affected Environment .................................................................................................. 4-18 4.7.2 Environmental Consequences ..................................................................................... 4-18

4.7.2.1 Construction ................................................................................................... 4-18 4.7.2.2 Operation ........................................................................................................ 4-20


4.8 Infrastructure and Utilities .......................................................................................................... 4-20 4.8.1 Affected Environment .................................................................................................. 4-20

4.8.1.1 Potable Water ................................................................................................. 4-20 4.8.1.2 Waste Water ................................................................................................... 4-21 4.8.1.3 Natural Gas ..................................................................................................... 4-21 4.8.1.4 Electricity ....................................................................................................... 4-21 4.8.1.5 Telecommunications....................................................................................... 4-21 4.8.1.6 Solid Waste..................................................................................................... 4-23

4.8.2 Environmental Consequences ..................................................................................... 4-23 4.8.2.1 Potable Water ................................................................................................. 4-23 4.8.2.2 Waste Water ................................................................................................... 4-23 4.8.2.3 Natural Gas ..................................................................................................... 4-23 4.8.2.4 Electricity ....................................................................................................... 4-23 4.8.2.5 Telecommunications....................................................................................... 4-23 4.8.2.6 Solid Waste..................................................................................................... 4-24


4.9 Cultural Resources ....................................................................................................................... 4-24 4.9.1 Affected Environment .................................................................................................. 4-26

4.9.1.1 Archaeological Resources .............................................................................. 4-26 4.9.1.2 Traditional Cultural Properties ....................................................................... 4-26 4.9.1.3 Architectural Resources .................................................................................. 4-26

4.9.2 Environmental Consequences ..................................................................................... 4-27 4.9.3 No Action Alternative ................................................................................................... 4-27 4.9.4 Mitigation ...................................................................................................................... 4-27

4.10 Water Resources ........................................................................................................................... 4-27 4.10.1 Affected Environment .................................................................................................. 4-27

4.10.1.1 Water Quality ................................................................................................. 4-28 4.10.1.2 Floodplains ..................................................................................................... 4-28 4.10.1.3 Wetlands and Waters of the U.S. .................................................................... 4-28


4.11 Biological Resources ..................................................................................................................... 4-31 4.11.1 Affected Environment .................................................................................................. 4-31

4.11.1.1 Vegetation ...................................................................................................... 4-31 4.11.1.2 Wildlife ........................................................................................................... 4-31 4.11.1.3 Federally Threatened and Endangered and State Listed

Special Status Species .................................................................................... 4-32 4.11.2 Environmental Consequences ..................................................................................... 4-34


Special Status Species .................................................................................... 4-35 4.11.3 No Action Alternative ................................................................................................... 4-35 4.11.4 Mitigation ...................................................................................................................... 4-35

4.12 Hazardous Materials and Waste ................................................................................................. 4-36 4.12.1 Affected Environment .................................................................................................. 4-36


iv Table of Contents July 2015

4.12.1.1 Hazardous Materials ....................................................................................... 4-36 4.12.1.2 Hazardous Wastes .......................................................................................... 4-36 4.12.1.3 Radon ............................................................................................................. 4-36

4.12.2 Environmental Consequences ..................................................................................... 4-37 4.12.2.1 Hazardous Materials ....................................................................................... 4-37 4.12.2.2 Hazardous Wastes .......................................................................................... 4-37 4.12.2.3 Radon ............................................................................................................. 4-38


5.0 ALTERNATIVE 2 – ROXANA ....................................................................................................................5-1

5.1 Land Use and Zoning ..................................................................................................................... 5-1 5.1.1 Affected Environment .................................................................................................... 5-1 5.1.2 Environmental Consequences ....................................................................................... 5-1 5.1.3 No Action Alternative ..................................................................................................... 5-1 5.1.4 Mitigation ........................................................................................................................ 5-1

5.2 Topography, Geology and Soils ..................................................................................................... 5-1 5.2.1 Affected Environment .................................................................................................... 5-1 5.2.2 Environmental Consequences ....................................................................................... 5-3 5.2.3 No Action Alternative ..................................................................................................... 5-3 5.2.4 Mitigation ........................................................................................................................ 5-3

5.3 Socioeconomics and Environmental Justice ................................................................................. 5-3 5.3.1 Affected Environment .................................................................................................... 5-3 5.3.2 Environmental Consequences ....................................................................................... 5-4 5.3.3 No Action Alternative ..................................................................................................... 5-4 5.3.4 Mitigation ........................................................................................................................ 5-4

5.4 Community Facilities and Services ............................................................................................... 5-4 5.4.1 Affected Environment .................................................................................................... 5-4

5.4.1.1 Police ................................................................................................................ 5-4 5.4.1.2 Fire ................................................................................................................... 5-4 5.4.1.3 Healthcare ......................................................................................................... 5-4 5.4.1.4 Schools ............................................................................................................. 5-4

5.4.2 Environmental Consequences ....................................................................................... 5-5 5.4.2.1 Police ................................................................................................................ 5-5 5.4.2.2 Fire ................................................................................................................... 5-5 5.4.2.3 Healthcare ......................................................................................................... 5-5 5.4.2.4 Schools ............................................................................................................. 5-5


5.5 Transportation and Traffic............................................................................................................ 5-5 5.5.1 Affected Environment .................................................................................................... 5-5 5.5.2 Environmental Consequences ....................................................................................... 5-6



5.6 Air Quality ...................................................................................................................................... 5-7 5.6.1 Affected Environment .................................................................................................... 5-7 5.6.2 Environmental Consequences ....................................................................................... 5-7

5.6.2.1 Construction ..................................................................................................... 5-7 5.6.2.2 Operations ........................................................................................................ 5-8


5.7 Noise ................................................................................................................................................. 5-8 5.7.1 Affected Environment .................................................................................................... 5-8 5.7.2 Environmental Consequences ....................................................................................... 5-8


Table of Contents v July 2015


5.8 Infrastructure and Utilities ............................................................................................................ 5-9 5.8.1 Affected Environment .................................................................................................... 5-9

5.8.1.1 Potable Water ................................................................................................... 5-9 5.8.1.2 Wastewater ....................................................................................................... 5-9 5.8.1.3 Natural Gas ....................................................................................................... 5-9 5.8.1.4 Electricity ......................................................................................................... 5-9 5.8.1.5 Telecommunications......................................................................................... 5-9 5.8.1.6 Solid Waste..................................................................................................... 5-11

5.8.2 Environmental Consequence ....................................................................................... 5-11 5.8.2.1 Potable Water ................................................................................................. 5-11 5.8.2.2 Wastewater ..................................................................................................... 5-11 5.8.2.3 Natural Gas ..................................................................................................... 5-11 5.8.2.4 Electricity ....................................................................................................... 5-11 5.8.2.5 Telecommunications....................................................................................... 5-11 5.8.2.6 Solid Waste..................................................................................................... 5-11


5.9 Cultural Resources ....................................................................................................................... 5-12 5.9.1 Affected Environment .................................................................................................. 5-12

5.9.1.1 Archaeological Resources .............................................................................. 5-12 5.9.1.2 Traditional Cultural Properties ....................................................................... 5-12 5.9.1.3 Architectural Resources .................................................................................. 5-12


5.10 Water Resources ........................................................................................................................... 5-14 5.10.1 Affected Environment .................................................................................................. 5-14 5.10.2 Environmental Consequences ..................................................................................... 5-16 5.10.3 No Action Alternative ................................................................................................... 5-16 5.10.4 Mitigation ...................................................................................................................... 5-16

5.11 Biological Resources ..................................................................................................................... 5-16 5.11.1 Affected Environment .................................................................................................. 5-16

5.11.1.1 Vegetation ...................................................................................................... 5-16 5.11.1.2 Wildlife ........................................................................................................... 5-17 5.11.1.3 Federal Listed Threatened and Endangered Species and

State Listed Threatened and Endangered Species .......................................... 5-17 5.11.2 Environmental Consequences ..................................................................................... 5-17


Special Status Species .................................................................................... 5-17 5.11.3 No Action Alternative ................................................................................................... 5-18 5.11.4 Mitigation ...................................................................................................................... 5-18

5.12 Hazardous Materials and Waste ................................................................................................. 5-18 5.12.1 Affected Environment .................................................................................................. 5-18

5.12.1.1 Hazardous Wastes .......................................................................................... 5-18 5.12.1.2 Radon ............................................................................................................. 5-19


6.0 RELATIONSHIP BETWEEN SHORT-TERM USE OF THE ENVIRONMENT

AND THE MAINTENANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY ..........................................................................................................................6-1


vi Table of Contents July 2015

7.0 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES ...............................7-1 8.0 CUMULATIVE IMPACTS ..........................................................................................................................8-1

8.1 Past, Present, and Reasonably Foreseeable Future Action ......................................................... 8-1 8.1.1 Letcher County Airport Project .................................................................................... 8-1 8.1.2 Gateway Regional Business Park .................................................................................. 8-2 8.1.3 Infrastructure and Utility Projects ............................................................................... 8-2 8.1.4 Proposed Action .............................................................................................................. 8-2 8.1.5 Potential Cumulative Impacts ....................................................................................... 8-4

9.0 REFERENCES ..............................................................................................................................................9-1 10.0 LIST OF PREPARERS ...............................................................................................................................10-1 11.0 DISTRIBUTION LIST ................................................................................................................................11-1 APPENDIX A AGENCY COORDINATION ....................................................................................................... A-1 APPENDIX B EXCAVATION AND GRADING CALCULATIONS ................................................................ B-1 APPENDIX C AIR EMISSION CALCULATIONS............................................................................................. C-1 APPENDIX D ENHANCED UTILITY REPORT ................................................................................................ D-1 APPENDIX E RESPONSES TO COMMENTS ................................................................................................... E-1 APPENDIX F TRAFFIC IMPACT STUDY ......................................................................................................... F-1

List of Figures

Figure 2-1. Payne Gap and Roxana Site Locations................................................................................................2-4 Figure 2-2. Payne Gap Project Location.................................................................................................................2-6 Figure 2-3. Payne Gap USP and FPC Conceptual Layout ....................................................................................2-7 Figure 2-4. Roxana Project Location ......................................................................................................................2-9 Figure 2-5. Roxana USP and FPC Conceptual Layout .......................................................................................2-10 Figure 4-1. Payne Gap Land Use .............................................................................................................................4-2 Figure 4-2. Payne Gap Existing Utilities ...............................................................................................................4-22 Figure 4-3. Payne Gap Architectural Resources ..................................................................................................4-25 Figure 4-4. Payne Gap Wetlands and Waters of the U.S. ...................................................................................4-30 Figure 5-1. Roxana Land Use ..................................................................................................................................5-2 Figure 5-2. Roxana Existing Utilities ....................................................................................................................5-10 Figure 5-3. Roxana Architectural Resources .......................................................................................................5-13 Figure 5-4. Roxana Wetlands and Waters of the U.S. .........................................................................................5-15


Table of Contents vii July 2015

List of Tables

Table ES-1. Summary of Environmental Consequences ......................................................................................... iv Table 1-1. Mid-Atlantic Region USP Inmate Population ......................................................................................1-3 Table 2-1. Estimated Site Preparation Quantities for Alternative 1 - Payne Gap ..............................................2-5 Table 2-2. Estimated Site Preparation Quantities for Alternative 2 - Roxana ....................................................2-8 Table 3-1. Ambient Air Quality Standards ............................................................................................................3-4 Table 3-2. Sound Levels Estimated by Population Density ...................................................................................3-5 Table 4-1. Study Area Population Trends, 2000-2010 ...........................................................................................4-5 Table 4-2. Study Area Employment, 2013 ..............................................................................................................4-6 Table 4-3. Study Area Percent Unemployment Rates ...........................................................................................4-6 Table 4-4. Study Area Personal and Per Capita Income .......................................................................................4-7 Table 4-5. Study Area Housing Units, 2013 ............................................................................................................4-7 Table 4-6. Study Area Percent Race and Ethnicity, 2013 .....................................................................................4-8 Table 4-7. Study Area Percent Race and Ethnicity, 2013 .....................................................................................4-8 Table 4-8. Study Area Percent Under the Age of 18, 2013 ....................................................................................4-8 Table 4-9. Letcher County Schools Enrollment and Capacity for 2014-2015 ...................................................4-12 Table 4-10. Estimated Peak Hour Trip Generation.............................................................................................4-14 Table 4-11. Construction Emission Estimates for Payne Gap Site .....................................................................4-16 Table 4-13. OSHA Permissible Noise Exposures .................................................................................................4-18 Table 4-14. Airborne Construction Related Noise Emissionsyu .........................................................................4-19 Table 4-15. Architectural Resources in the Payne Gap Site APE Evaluated for NRHP

Eligibility..............................................................................................................................................4-27 Table 4-16. Wetland and Streams Delineated at Payne Gap ..............................................................................4-29 Table 4-17. State and Federal Report of Endangered, Threatened, and Special Concern

Plants, Animals, and Natural Communities of Letcher County, Kentucky ...................................4-32 Table 5-1. Estimated Peak Hour Trip Generation ................................................................................................5-7 Table 5-2. Construction Emission Estimates for Roxana Site ..............................................................................5-8 Table 5-3. Architectural Resources in the Roxana Site APE Evaluated for NRHP

Eligibility..............................................................................................................................................5-12 Table 5-4. Wetland and Streams Delineated at Roxana ......................................................................................5-14 Table 8-1. Estimated GHG Emissions from Construction Activities at Payne Gap Site ....................................8-3 Table 8-2. Estimated GHG Emissions from Construction Activities at Roxana Site .........................................8-3 Table 8-3. Estimated GHG Emissions from Operations at Either Site ................................................................8-4


viii Table of Contents July 2015



Acronyms and Abbreviations ix July 2015

ACRONYMS AND ABBREVIATIONS

ac acres

AEP American Electric Power

AMSL above mean sea level

AMU Adjusted Mitigation Units

APE Area of Potential Effects

ARH Appalachian Regional Healthcare

ASTMI American Society for Testing and Materials International

BMPs Best Management Practices

BOP Bureau of Prisons

CAA Clean Air Act

CEQ Council on Environmental Quality

CFR Code of Federal Regulations

CH4 methane

CMOA Conservation Memorandum of Agreement

CO carbon monoxide

CO2e carbon dioxide equivalent

CWA Clean Water Act

dB decibels

dBA A-weighted decibels

EA Environmental Assessment

EIS Environmental Impact Statement

EIU Ecological Integrity Unit

EMTs emergency medical technicians

EO Executive Order

E&S Erosion and Sedimentation

ESA Endangered Species Act

FPC Federal Prison Camp

FPPA Farmland Protection Policy Act

GHGs greenhouse gases

HAP hazardous air pollutants

ITE Institute of Transportation Engineers

KDEP Kentucky Department of Environmental Protection

KGS Kentucky Geological Survey

KHC Kentucky Heritage Council

KRADD Kentucky River Area Development District

KYLMI Kentucky Labor Market Information

KYTC Kentucky Transportation Cabinet

LCPC Letcher County Planning Commission

LOS level of service

LWSD Letcher County Water and Sewer District

MBTA Migratory Bird Treaty Act

MOU Memorandum of Understanding

MSAT(s) Mobile Source Air Toxic(s)

MSL mean sea level

NAAQS National Ambient Air Quality Standards

NEPA National Environmental Policy Act

NHPA National Historic Preservation Act

NO2 nitrogen dioxide

NOx nitrogen oxides

NRCS Natural Resources Conservation Service

NRHP National Register of Historic Places

NWI National Wetland Inventory

O3 ozone

OSHA Occupational Safety and Health Administration

PM2.5 particulate matter with a diameter of 2.5 microns or less

PM10 particulate matter with a diameter less than 10 microns

ppb parts per billion

ppm parts per million

psi pounds per square inch

RCRA Resource Conservation and Recovery Act

SHPO State Historic Preservation Officer

SO2 sulphur dioxide

TCPs Traditional Cultural Properties

TMDL Total Maximum Daily Load

TPY tons per year

TRI Toxics Release Inventory

TSCA Toxic Substances Control Act


x Acronyms and Abbreviations July 2015

U.S. United States

USACE U.S. Army Corps of Engineers

USC U.S. Code

USEPA U.S. Environmental Protection Agency

USFWS U.S. Fish and Wildlife Service

USGS U.S. Geological Survey

USP U.S. Penitentiary

VOC volatile organic compound WWTP wastewater treatment plant

yd3 cubic yards

µg/m3 micrograms per cubic meter

µS microseconds

Final Environmental Impact Statement for Proposed USP and FPC Letcher County, Kentucky

1.0 Purpose and Need for Proposed Action 1-1 July 2015

1.0 PURPOSE AND NEED FOR THE PROPOSED ACTION

The United States (U.S.) Department of Justice, Federal Bureau of Prisons (Bureau) has prepared this Final Environmental Impact Statement (EIS) in accordance with the National Environmental Policy Act (NEPA) of 1969, the Council on Environmental Quality (CEQ) regulations implementing NEPA (40 Code of Federal Regulations [CFR] 1500-1508, and the Department of Justice procedures for implementing NEPA (28 CFR 61). The Bureau’s Final EIS evaluates the potential environmental consequences of the proposed construction and operation of a federal correctional facility in Letcher County, Kentucky. Two action alternatives and the No Action Alternative are assessed.

BACKGROUND 1.1

The Bureau was established in 1930 to provide more progressive and humane care for federal inmates, to professionalize the prison service, and to ensure consistent and centralized administration of federal prisons. The mission of the Bureau is to protect society by confining offenders in the controlled environments of prisons and community-based facilities that are safe, humane, cost efficient, and appropriately secure, and that provide work and other self-improvement opportunities to assist offenders in becoming law-abiding citizens.

SECURITY LEVELS 1.2

The Bureau accomplishes its mission through the appropriate use of the following types of community-correction, detention, and correctional facilities:

• Federally owned and operated • Federally owned and non-federally operated • Non-federally owned and operated

Regardless of facility ownership, the Bureau operates correction and detention facilities at various security levels. Each security level is characterized by the type of housing within the institution, internal security features, and staff-to-inmate ratio. Different security levels require particular features such as external patrols, guard towers, security barriers, or detection devices. The five categories of security levels are described as follows:

• Minimum-Security – Also known as Federal Prison Camps (FPCs) or satellite work camps. They are characterized by dormitory housing, a relatively low staff-to-inmate ratio, and are without fences. They are typically associated with a larger institution or military base where inmates can help serve labor needs of the institution or base.

• Low-Security – Federal Correctional Institutions with double fenced perimeters, primarily dormitory housing, and strong work and program components.

• Medium-Security – Federal Correctional Institutions with strengthened perimeters (e.g., double fences with electronic detection systems), cell-type housing, a wide variety of work and treatment programs, and an increased inmate-to-staff ratio to provide greater control.

• High-Security – Also known as United States Penitentiary (USP). These facilities have highly secure perimeters (e.g., walls or double fences with taut wire fencing, non-lethal/lethal fences), multiple single occupant cell housing, guard towers, close staff supervision, and movement controls.


1-2 1.0 Purpose and Need for Proposed Action July 2015

• Administrative – Institutions that house offenders who require an uncommon level of security due to their serious records of institutional misconduct, involvement in violent or escape-related behavior, and/or who have unusual security needs based on the nature of their offense. These facilities have highly secured perimeters consisting of walled or double fenced enclosures with guard towers.

EXISTING FEDERAL PRISON POPULATION 1.3

In 1981, the federal inmate population consisted of approximately 23,800 inmates. By 1986 the federal inmate population had increased to about 38,700: a 63 percent increase. Growth continued at a steady rate through the 1990s and in 1998 the federal inmate population had grown 280 percent, reaching 108,000 inmates. As of November 7, 2014, the Bureau inmate population reached 213,620; this includes 171,744 inmates being housed in 120 Bureau institutions, 27,627 being housed in privately-managed secure facilities, and 14,249 being housed in other contract care. Of the 171,744 inmates housed in Bureau institutions, 23,988 are high-security inmates. The Bureau houses these 23,988 high-security inmates in 19 USPs located throughout six regions within the U.S.: the Mid-Atlantic Region; North Central Region; Northeast Region; South Central Region; Southeast Region; and Western Region. Each region provides facilities for housing inmates at all security levels. The 19 USPs are rated for a total capacity of 14,274 high-security inmates. Therefore, the Bureau’s high-security institutions are currently 52 percent overcrowded and are operating at above rated capacity.

To meet the current and projected bedspace needs, the Bureau evaluates the bedspace needs of the regions using a geographically balanced program. When considering placement of an individual, the Bureau considers the origin of the inmate and attempts to place the inmate in an institution that is within the region of the inmate’s origin. Placing inmates within their region of origin provides greater opportunity for visitation with family, which aids in the rehabilitation process.

FEDERAL BUREAU OF PRISONS MID-ATLANTIC REGION 1.4

One of the regions identified by the Bureau as having an increasing need for additional high-security bedspace in order to reduce overcrowding in the Mid-Atlantic Region. Approximately 5,802 inmates, including those in special programs, are housed within the Mid-Atlantic Region. The current rated capacity for these institutions is 3,400. Therefore, the Bureau has determined that due to the overcrowding in the Mid-Atlantic Region, specifically within the USPs and FPCs, that construction of a new high-security facility would be warranted in the region.

There are currently 15 correctional facilities within the Bureau’s Mid-Atlantic Region. Of these, only four are USPs or high-security facilities: USP Hazelton located in Hazelton, West Virginia, USP Lee located in Jonesville, Virginia, USP Big Sandy located in Inez, Kentucky, and USP McCreary located in McCreary, Kentucky. Table 1-1 depicts the current populations associated with each of the USPs in the Mid-Atlantic Region.



Table 1-1. Mid-Atlantic Region USP Inmate Population

USP

Existing Inmate Population (does not include those in special

programs) Rated Capacity Hazelton 1,440 840 Lee 1,430 880 Big Sandy 1,245 800 McCreary 1,322 880

Total 5,802 3,400

PURPOSE AND NEED 1.5

The purpose of the proposed federal correctional facility in Letcher County, Kentucky, is to develop additional high-security and medium-security facilities to increase capacity for current inmate populations in the Mid-Atlantic Region. The need for the proposed facility is that the current inmate populations of the USPs in the Mid-Atlantic Region are exceeding their rated capacity and their associated FPCs are at or near capacity. The Bureau has determined that there is a need for additional high-security and medium- security facilities within this region to reduce the demonstrated overcrowding that compromises the mission of the Bureau. The Bureau’s mission is to protect society by confining offenders in the controlled environments of prisons and community-based facilities that are safe, humane, cost-efficient, and appropriately secured, and that provide work and other self-improvement opportunities to assist offenders in becoming law-abiding citizens.

PROPOSED ACTION 1.6

The proposed action being evaluated in this Final EIS is the acquisition of property and the construction and operation of a federal correctional facility in Letcher County, Kentucky. The Bureau proposes to acquire approximately 800 acres (324 hectares) to construct a USP (approximately 61,654 square meters [663,638 square foot]) and FPC (approximately 6,063 square meters [65,262 square foot]) in Letcher County. Inmates housed in the USP would be high-security male inmates and those housed in the FPC would be minimum-security male inmates. The proposed facilities would house approximately 1,216 total inmates (approximately 960 within the USP and approximately 256 within the FPC). In addition to the USP and FPC, several ancillary facilities necessary for the operation of the USP and FPC would be constructed. A non-lethal/lethal fence would also be installed around the perimeter of the USP. The non-lethal/lethal fence would be placed between two parallel, chain link and razor wire fences. The fence would be approximately 12 feet high. The ancillary facilities would include the following:

• Central Utility Plant-1,217 square meters (13,100 square foot) • Firing Range-96 square meters (1,033 square foot) • Outside Warehouse-3,279 square meters (35,295 square foot) • Staff Training Building-910 square meters (9,795 square foot) • Garage/Landscape Building-653 square meters (7,028 square foot) • Access Roads

Operation of the USP and FPC would employ approximately 300 full-time staff.



General Design Features of the United States Penitentiary and Federal Prison Camp 1.6.1

The Bureau has standard design layouts for their correctional facilities that include similar design characteristics. General design features of a USP include:

• Single road for controlled access to each correctional facility, • Parking lot located near the public entrance to each correctional facility for use by both

employees and visitors, • One- to four-story structures, • Multipurpose activity spaces, and • Buffer areas around the facility providing visual and physical setbacks from the site boundaries.

ENVIRONMENTAL REVIEW PROCESS 1.7

National Environmental Policy Act 1.7.1

In 1969, Congress enacted the National Environmental Policy Act (NEPA), which requires consideration of environmental issues in federal agency planning and decision-making. Regulations for federal agency implementation of the act were established by the President’s CEQ. NEPA requires federal agencies to prepare an environmental assessment (EA) or environmental impact statement (EIS) for any federal action, except those actions that are determined to be “categorically excluded” from further analysis. An EIS is prepared for those federal actions that may significantly affect the quality of the human and natural environments or where the impacts are largely unknown or controversial. The EIS must disclose significant environmental impacts and inform decision makers and the public of the reasonable alternatives that would avoid or minimize adverse impacts or enhance the quality of the human environment. The intent of this EIS is to document the potential environmental impacts associated with the proposed action, acquisition of property and construction and operation of a USP and FPC. The Bureau is the decision-maker with regard to this proposed action. This document, together with its appendices and other documents incorporated by reference, constitutes the Final EIS pursuant to NEPA, the CEQ regulations, and the Department of Justice procedures for implementing NEPA.

The Final EIS evaluates environmental impacts to: land use and zoning; topography, geology, and soils; socioeconomics and environmental justice; community facilities and services (fire and police services, emergency services, health care facilities, etc.); transportation and traffic; air quality; noise; infrastructure and utilities; cultural resources (historic properties, archaeology); water resources; biological resources (threatened and endangered species, wetlands, vegetation, etc.); and hazardous materials and waste. The evaluation will determine the potential impacts of the proposed action and, if necessary, where impacts may be avoided or minimized, as well as if the impacts would require mitigation. The evaluation of the proposed sites will also determine which site would result in the least amount of impact to the environment.

Related Environmental Documents 1.7.2

In 2008, the Bureau conducted a site reconnaissance study in Letcher County, Kentucky. The site reconnaissance report identified several resources associated with potential sites that would require additional studies to determine if the sites were viable for the development of a federal correctional institution. Based on this 2008 study, a second study was conducted in 2010 to rank these sites and verify that the issues originally identified in 2008 had not changed. Based on the data collected from both the



2008 and 2010 studies, it was determined that a feasibility study to analyze the resources of concern would be conducted to further assess the viability of construction at each of the sites.

In 2012 a feasibility study was completed by the Bureau to evaluate four potential sites for the development of a USP and FPC in Letcher County, Kentucky (TEC, Inc. 2012). The purpose was to conduct additional studies, including wetland identification and delineation, cultural resource surveys, geotechnical studies, boundary surveys, and a utility assessment of the proposed sites to determine if there would be constraints associated with these resources and the development of the sites. The feasibility study evaluated the benefits, challenges, and potential risks associated with development of each site. Based on the results of the feasibility study and changes with the offers of sites, it was determined that two sites, Payne Gap and Roxana, would be carried forward for analysis in this Final EIS.

Agency Coordination 1.7.3

In addition to NEPA, other laws, regulations, permits and licenses may be applicable to the proposed action. Specifically, the proposed action may require:

• Informal consultation with U.S. Fish and Wildlife (USFWS) Service regarding the occurrence of threatened and endangered species within the sites;

• Concurrence from the State Historic Preservation Officer on cultural resource findings; • Clean Water Act Section 404 permit if wetland impacts occur; • National Pollutant Discharge Elimination permit for non-point source discharge; and • Erosion and sedimentation control plan for new construction.

Public Involvement 1.7.4

NEPA requires the public be informed and involved throughout the development of the EIS, beginning with public scoping. The public scoping meeting is an opportunity for the federal agency, in this case the Bureau, to introduce the project to the public and receive input on the scope of the issues to be addressed in the EIS. The local public has knowledge of the area where the proposed action may take place, and can provide insight into local resources, as well as to the concerns of the community. Public involvement in the NEPA process is required and is an extremely valuable tool in the successful completion of NEPA documents.

The official scoping period for this project began when the Bureau published a Notice of Intent to prepare an EIS on July, 26, 2013, in the Federal Register, and lasted until August 26, 2013. A scoping meeting was held on August 13, 2013 to inform the public about the proposed project and to explain NEPA and the associated environmental impact analysis. A total of 453 people attended the public meeting and a total of 320 comments were received during the 30-day scoping period. Additionally, 169 letters of support were presented at the public meeting, as well as two petitions in support of the project with a total of 124 signatures. Of the 320 comments received, 317 comments were in support of the project and 3 were not in support of the project. Issues raised in the letters that did not support the project included: socioeconomics, previous mining activities, infrastructure, and alternatives. These resources and areas of concern raised during scoping were analyzed in the Draft EIS.

The Notice of Availability of the Draft EIS was published in the Federal Register on February 13, 2015. A Notice of Public Meeting for the Draft EIS was published in the Federal Register on February 10, 2015. The notice provided the date, time, and location of the public meeting to be held on March 12, 2015. A notice of the availability of the Draft EIS and public meeting was also published in the Mountain



Eagle on February 11, 2015 and the Lexington Herald on February 8, 2015. The notice announced that the Draft EIS would be available for public review and comment between February 13 and March 30, 2015. The notice identified the local libraries where hard copies of the document could be reviewed, as well as a project website, www.fbopletchercountyeis.com, where an electronic version of the document could be reviewed. The Bureau also sent out 60 hardcopies and 161 CDs containing the Draft EIS to federal, state, and local elected officials and regulatory agencies (USFWS, U.S. Army Corps of Engineers, Kentucky State Clearinghouse, etc.), other interested parties (planning commission, fire departments, police departments, etc.), and individuals who had requested a copy during scoping or at any other time prior to the release of the Draft EIS.

The public meeting was held on March 12, 2015 between 5:30 p.m. and 8:00 p.m. at the Letcher County Central High School. The meeting was conducted in an open house format and Bureau representatives were in attendance to answer questions and discuss the project with the attendees. Approximately 350 members of the public attended the public meeting. Attendees were able to provide written comments or give oral comments to a stenographer during the meeting. Attendees were also provided information for mailing their comments to the Bureau. Comments received during the public comment period included 158 comments received at the public meeting; 31 comments received via mail or email; three petitions in support of the project with 1,001 signatures, one petition in support of the project at the Roxana site with 155 signatures, and 1,005 letters of support. Of the comments received, 1,157 of the comments (not including the petitions in support of the project) were in support of the project and 12 comments were in opposition of the project. Twenty-four of the comments in support of the project favored the Payne Gap site and 44 of the comments in support of the project favored the Roxana site.

http://www.fbopletchercountyeis.com/


2.0 Alternatives 2-1 July 2015

2.0 ALTERNATIVES

CEQ’s guidelines for implementing the procedural Provisions of the NEPA establish a number of policies for federal agencies, including “…using the NEPA process to identify and assess reasonable alternatives to the proposed action that will avoid or minimize adverse effects of these actions on the quality of the human environment” (40 CFR 1500.2[e]). The guidelines also require an analysis of alternatives based “on the information and analysis presented in the sections on the Affected Environment (§1502.15) and the Environmental Consequences (§1502.16).” The guidelines further state that the analysis “should present the environmental impacts of the proposal and the alternatives in comparative form, thus sharply defining the issues and providing a clear basis for choice.” According to CEQ guidelines the alternatives analysis is also required to:

• “Include the alternative of no action”; • “…explore and objectively evaluate all reasonable alternatives, and for alternatives which were

eliminated from detailed study, briefly discuss the reasons for their having been eliminated”; • “Devote substantial treatment to each alternative considered in detail including the proposed

action so that reviewers may evaluate their comparative merits”; • “Include reasonable alternatives not within the jurisdiction of the lead agency”’; • “Identify the agency’s preferred alternative or alternatives, if one or more exists, in the draft

statement and identify such alternative in the final statement unless another law prohibits the expression of such a preference”; and

• “Include appropriate mitigation measures not already included in the proposed action or alternatives.”

The analysis of alternatives considered in this EIS was conducted under these guidelines to address the following:

• No Action Alternative. A decision not to proceed with the proposed action to develop a new USP and FPC.

• Alternative Locations-Nationwide. Locations other than the Letcher County, Kentucky area for implementation of the proposed action.

• Alternative Locations. Within the Geographic Area of Interest Warranting Consideration. Potential site(s) which meet minimum requirements for accommodating the proposed facility; are located with the geographic area of interest (Kentucky); and have been offered and are available for Bureau consideration.

A discussion of these alternatives follows. No reasonable alternatives outside the jurisdiction of the Bureau (the lead agency) have been identified or warrant inclusion in the EIS.

NO ACTION ALTERNATIVE 2.1

Under the No Action Alternative, the Bureau would not acquire property or construct and operate a new USP or FPC. Existing USPs would remain overcrowded and prevent the Bureau from meeting its mission. The No Action Alternative would avoid potential impacts associated with the development of a USP and FPC. The No Action Alternative does not meet the project purpose and need and is therefore, not considered a viable alternative. The No Action Alternative is discussed in this EIS because it serves as a baseline against which to compare the action alternatives.


2-2

ALTERNATIVE LOCATIONS-NATIONWIDE 2.2

The locations of new federal correctional facilities are determined by the need for incarceration in various regions of the country and the resources available to meet that need. To meet these needs the Bureau routinely identifies and evaluates potential sites that may be appropriate for development of new federal correctional facilities. Under an ongoing Congressional mandate, consideration is given to surplus properties while other publicly- or privately-owned properties offered to the Bureau are also examined for possible use.

The initial steps in the planning process include the identification and evaluation of potential sites. Identification of a site that has the potential to house more than one federal correctional facility is a key factor in the evaluation of sites. Acquisition of property that has the potential for facility expansion provides the Bureau with the opportunity to expand as the inmate population grows. The Bureau also responds to initiatives from communities requesting consideration to host new federal correctional facilities. When approached by a community to host a facility, the Bureau’s first steps are to visit the sites offered and:

• Identify the interest and support of the community, including the support/opposition of elected and appointed officials, community leaders, stakeholders, and the general public in having a federal correctional facility within their community.

• Identify suitable locations for development of the federal correctional facility based on infrastructure conditions, environmental resources, land use and zoning, and other related criteria.

• Determine the on-site conditions including constructability of the site. • Identify potential environmental issues that require consideration under NEPA (National Historic

Preservation Act [NHPA], Clean Water Act, Endangered Species Act, etc.). • Determine what further investigations and detailed studies may be warranted to obtain additional

information about the potential sites.

After the initial screening process, those sites with favorable conditions are moved forward and evaluated under another set of criteria, including optimal infrastructure and environmental requirements. The criteria used to evaluate the sites are established by the Bureau; however, these general criteria can be supplemented if needed to assess issues or potential issues and make sure they are addressed adequately in the evaluation of the sites. The general criteria the Bureau uses to screen potential sites for development include:

• The site should have sufficient land area (300 to 350 acres minimum [121 to 142 hectares]) to accommodate the institution and ancillary facilities, provide a buffer zone between the facility and neighboring properties, and allow for future expansion.

• Proposed site should be relatively flat (less than 10 percent grade) to provide for minimal site preparation and proper drainage (this can be affected by geographic regions with mountainous terrain).

• Sites should avoid significant environmental resources (i.e., floodplains, wetlands, threatened and endangered species, cultural and historic resources, etc.).

• Sites should avoid potential incompatible land use conflicts. • Emergency services, including police and fire protection, and utilities should be able to provide

services to the prospective sites.



• Site should be served by well-maintained state and county roadways to ensure safe commutes for employees, service vehicles, and visitors.

• Support of key elected officials, community leaders, the public and owners of the sites.

Sites that the Bureau determines meet these general criteria, and are viable for the development of a federal correctional facility, are then evaluated in more detail in either an EA or EIS, in compliance with NEPA.

ALTERNATIVES DEVELOPMENT 2.3

The Bureau has a priority need for additional facilities within the Bureau’s Mid-Atlantic Region, which includes the State of Kentucky. The Bureau was contacted by the Letcher County Planning Commission (LCPC) with an offer of potential sites for a new USP and FPC in Letcher County, Kentucky. Understanding the needs of the Bureau, the LCPC identified potential locations for development and brought these sites to the attention of the Bureau to determine if the Bureau had an interest in developing a new facility at one of the locations. The opportunity to provide additional bedspace in Letcher County would meet the need for additional capacity within the Mid-Atlantic Region, afford the Bureau continued management of inmates originating from the region, and allow those inmates to remain close to family and friends.

The process to identify potential sites for constructing a USP and FPC in Letcher County began in 2008 with site reconnaissance studies of four sites that had been offered to the Bureau by members of the community. The purpose of the site reconnaissance studies was to collect preliminary data on the sites and determine their suitability for development based on site conditions, infrastructure and utilities, and environmental resources. Based on this initial analysis, it was determined that the four sites evaluated should be studied in more detail in a feasibility study: Meadow Branch, Payne Gap, Roxana, and Van/Fields. The feasibility study provided an opportunity for more detailed analysis of each site and identified constraints that may eliminate a site from further consideration. In 2011, the Bureau completed a feasibility study that assessed cultural resources, wetlands, geologic conditions, and infrastructure. The feasibility study also included the production of aerial and topographic mapping, and a boundary survey. During the initial phases of the feasibility study, the Meadow Branch site was removed from further consideration due to changes with the offeror, and the site no longer available for consideration by the Bureau; therefore, no detailed analysis of the site was included in the feasibility study. During the feasibility study for the remaining three sites, wetlands were delineated, archaeological and historic structures surveys were completed, and geotechnical studies were conducted. The feasibility study highlighted potential concerns with development of the sites, as well as estimated costs of infrastructure improvement and site preparation (excavation and/or fill at each site, and grading activities) on each site. The feasibility study determined that there were no constraints that would prevent development of the three sites (TEC, Inc. 2012). During the finalization of the feasibility study there were changes with the offeror of the Van/Fields site, and this site was removed from further consideration. The remaining two sites, Payne Gap and Roxana, were identified as alternatives to be carried forward for study in an EIS (Figure 2-1).


2-4 2.0 Alternatives July 2015

Figure 2-1. Payne Gap and Roxana Site Locations



ALTERNATIVE 1 – PAYNE GAP 2.4

Under Alternative 1, the Bureau would acquire approximately 753 acres (305 hectares) of land known as the Payne Gap (Payne Gap) site. The site is located in eastern Letcher County, approximately 7 miles northeast of Whitesburg, along the Kentucky and Virginia border (Figures 2-1 and 2-2). The Bureau would then construct and operate a USP and FPC on this site. The site is situated on a gently sloped to steeply sloped upland land form above the Kentucky River at its confluence with the Laurel Fork. U.S. Route 119 is located along the north end of the proposed site and would provide site access. The site is forested with secondary growth forests and the original topography of portions of the site have been altered by past surface mining and associated mining activities such as spoil piles, roads, and fill piles. Mining permit applications indicate surface and underground mining operations have occurred within the proposed project site since the 1950s. Figure 2-3 depicts the proposed conceptual layout of the facility at the Payne Gap site. To accommodate the USP, FPC, ancillary buildings, and roads as described in Section 1.6, Proposed Action, the site would require extensive excavation and fill material to level and prepare the site for construction. Excavation of the site would include the removal of mine spoil. No slurry ponds or coal mine waste facilities are located on or near the Payne Gap site (U.S. Environmental Protection Agency [USEPA] 2015a, USEPA 2015b, and Sierra Club 2015). No active mining is occurring on site. The Bureau would require a minimum of 300 acres (121 hectares) for construction of the USP and FPC at this site. Table 2-1 depicts the site preparation quantities.

Table 2-1. Estimated Site Preparation Quantities for Alternative 1 - Payne Gap Activity Quantity

Spoil Excavation 2,794,660 yd3 Rock Excavation 8,117,470 yd3 Structural Fill 1,716,095 yd3 Spoil Fill 12,106,917 yd3 Dynamic Compaction 0 Clear Mined Area 7 ac (3 ha) Clear Forest Area 211 ac (85 ha)

Notes: yd3 = cubic yards, ac = acres, ha = hectares.



Figure 2-2. Payne Gap Project Location



Figure 2-3. Payne Gap USP and FPC Conceptual Layout



ALTERNATIVE 2 – ROXANA 2.5

Under Alternative 2, the Bureau would acquire approximately 700 acres (283 hectares) of land known as the Roxana site. The site is located 7.5 miles west of Whitesburg, Kentucky (Figures 2-1 and 2-4). The Bureau would construct and operate a USP and FPC on this site. Figure 2-5 depicts the proposed conceptual layout of the facility at the Roxana site. To accommodate the USP, FPC, ancillary buildings, and roads as described in Section 1.6, Proposed Action, the site would require extensive excavation of spoil material and lesser amounts of structural fill and spoil fill. Preparation of the site for construction activities would also require dynamic compaction, clear mined area, and forest clearing. Excavation of the site would include the removal of mine spoil. No slurry ponds or coal mine waste facilities are located on or near the Roxana site (USEPA 2015a, USEPA 2015b, and Sierra Club 2015). No active mining is occurring on site. The Bureau would require a minimum of 300 acres (121 hectares) for construction of the USP and FPC at this site. Table 2-2 depicts site preparation quantities.

Table 2-2. Estimated Site Preparation Quantities for Alternative 2 - Roxana Activity Quantity

Spoil Excavation 2,928,992 yd3 Rock Excavation 902,757 yd3 Structural Fill 2,087,607 yd3 Spoil Fill 2,205,394 yd3 Dynamic Compaction 25 ac Clear Mined Area 82 ac Clear Forest Area 79 ac

PREFERRED ALTERNATIVE 2.6

Alternative 2-Roxana is the preferred alternative because it best meets the project needs and, on balance, would have fewer impacts to the human environment. Threatened and endangered species was also a factor in the identification of the preferred alternative. Studies identified both summer roosting habitat and winter hibernaculum at the Payne Gap site. Identification of the winter bat hibernaculum would require additional studies to determine the extent of winter hibernaculum and impacts to the hibernaculum. Additionally, the site would impact a significant amount of summer roosting habitat versus the amount that would be impacted at the Roxana site. The Payne Gap site would also have significant impacts to wastewater and natural gas infrastructure, while the Roxana site would have less than significant impacts to infrastructure and utilities. Based upon comparison of these and other potential environmental impacts applicable to each site, including wetlands and stream impacts and significantly greater site preparation required for the Payne Gap site, the Roxana site would have fewer natural resource and other environmental impacts. Therefore, the Roxana site has been determined to be the preferred alternative.



Figure 2-4. Roxana Project Location



Figure 2-5. Roxana USP and FPC Conceptual Layout


3.0 Definition of Resource 3-1 July 2015

3.0 DEFINITION OF RESOURCE

LAND USE AND ZONING 3.1

Land use often refers to human modification of land for residential or economic purposes. Land use categories typically include agriculture (includes livestock production), forestry, residential, commercial, industrial, transportation, utilities, mining, recreation, and communication. Land uses are frequently regulated by management plans, land use plans, comprehensive plans, and local zoning and ordinances. These plans and regulations assist in identifying where future development can occur so it is compatible with surrounding land uses and, in protecting specially designated or environmentally sensitive uses.

Land use is interrelated with other resource areas including noise, socioeconomics, biological resources, and cultural resources. The impact analysis in this EIS for land use focuses on those areas affected by proposed construction and operation of the USP and FPC.

TOPOGRAPHY, GEOLOGY, AND SOILS 3.2

Topography describes the physical surface of the land and includes elevation, slope, and other general surface features. Geologic factors influence soil stability, bedrock depth, and seismic properties. Soil is the unconsolidated material above bedrock. Soil is formed from the weathering of bedrock and other parent materials.

The Farmland Protection Policy Act (FPPA) (7 U.S. Code [USC] 4201 et seq.) was introduced to conserve farmland soil and discourage the conversion of prime farmland soil to a non-agricultural use. The FPPA considers prime farmland soils as those that have the best combination of physical and chemical characteristics for producing food, feed, forage, fiber, and oilseed crops, and are also available for these uses. It has the soil quality, growing season, and moisture supply needed to economically produce sustained high yields of crops when treated and managed. Soils of statewide importance are those soils that are nearly prime farmland and that economically produce high yields of crops when treated and managed according to acceptable farming methods. The FPPA is based on the protection of prime farmland soils and not on whether the area is in agricultural use.

Topography, geology, and soil resources are analyzed in this EIS in terms of drainage, excavation and fill activities, erosion, and prime farmland. The analysis focuses on the area of soils that would be disturbed, the potential for erosion of soils from construction areas, and the potential for eroded soils to become pollutants in downstream surface water during storm events. Best Management Practices (BMPs) are identified to minimize soil impacts and prevent or control pollutant releases into stormwater.

SOCIOECONOMICS AND ENVIRONMENTAL JUSTICE 3.3

Socioeconomics describes the basic attributes and resources associated with the human environment, particularly population, employment, income, and housing. The affected area for socioeconomics is defined as the area where principal effects arising from the construction and operation of the proposed USP and FPC are likely to occur. The proposed action alternatives have the potential to cause socioeconomic impacts to the communities around the proposed sites through changes or relocation of Bureau personnel and construction expenditures.


3-2 3.0 Definition of Resource July 2015

Executive Order (EO) 12898, Federal Actions to Address Environmental Justice in Minority and Low-Income Populations (Environmental Justice), was issued in 1994. It stipulates that each federal agency is to make achieving environmental justice a part of its mission by identifying and addressing disproportionately high and adverse human health or environmental effects of their programs, policies, and activities on minority and low-income populations. A minority population is defined as either: 1) the minority population of the affected area exceeds 50 percent, or 2) the minority population percentage of the affected area is meaningfully greater than the minority population percentage in the appropriate community of comparison. Low-income populations are identified where a meaningfully greater portion of the population is living below the poverty level threshold as compared to the appropriate community of comparison (CEQ 1997). The environmental justice analysis in this EIS addresses the characteristics of race, ethnicity, and poverty status for populations residing in the immediate area of the proposed USP and FPC.

EO 13045, Protection of Children from Environmental Health Risks and Safety Risks (Protection of Children) was issued in 1997 requiring federal agencies to identify and assess environmental health risks and safety risks that may disproportionately affect children. It also requires that each federal agency is to ensure that its policies, programs, activities, and standards address disproportionate risks to children that result from environmental health risks or safety risks. In this EIS, the protection of children analysis addresses the population under 18 residing in areas potentially affected by the construction and operation of the proposed USP and FPC.

This socioeconomic analysis focuses on impacts due to population changes and construction expenditures. Economic impacts are defined to include direct effects, such as changes to employment, payrolls, and expenditures that affect the flow of dollars into the local economy and secondary effects, which result from the “ripple effect” of spending and re-spending in response to the direct effects.

Socioeconomic impacts, particularly impacts such as those being evaluated in this EIS, are often mixed: beneficial in terms of gains in jobs, expenditures, tax revenues, etc., and adverse in terms of growth management issues such as demands for housing and community services.

This analysis in this EIS identifies potential environmental justice issues. Impacts to environmental justice populations are identified where high and adverse human health or environmental effects may disproportionately affect minority or low-income populations. Impacts to children would occur if there was an increased disproportionate environmental, health, or safety risk to children.

COMMUNITY FACILITIES AND SERVICES 3.4

Community services include police protection, fire protection, healthcare services and schools. The potentially affected area includes the cities, towns, and county where the proposed sites are located and where Bureau employees associated with the proposed action would live and work.

The analysis in this EIS focuses on the existing conditions of community services within the adjacent communities in terms of capacity and availability. The anticipated demand for community services is described in relation to proposed population increases in inmates, Bureau personnel, and their families. Lastly, the analysis describes ability of community services to accommodate anticipated changes in the demand for those services resulting from the proposed action.



TRANSPORTATION AND TRAFFIC 3.5

Transportation and traffic refers to vehicle movement throughout a road and highway network. The study area for transportation and traffic includes the road and highway networks that surround and support the Payne Gap and Roxana sites. The American Association of Highway and Transportation Officials classify roadways as principal arterials, minor arterial streets, collector streets, and local streets. Principal arterials (i.e., arterial highways and interstates) serve to move traffic regionally and between population and activity centers with a minimal level of access to adjacent properties. Collector roadways (i.e., minor arterial and collector streets) serve to move traffic from population and activity centers and funnel them onto principal arterials with a moderate level of access to adjacent properties. Local roadways provide access to adjacent properties and move traffic onto collector and arterial roadways.

Average daily traffic and design capacity of the roadway represent two parameters to measure traffic (Transportation Research Board 2010). Using these two measures of traffic, each roadway segment receives a corresponding level of service (LOS). The LOS designation is a professional industry standard used to describe the operating conditions of a roadway segment or intersection. The LOS is defined on a scale of A to F that describes the range of operating conditions on a particular type of roadway facility. LOS A through LOS B indicates free flow travel. LOS C indicates stable traffic flow. LOS D indicates the beginning of traffic congestion. LOS E indicates the nearing of traffic breakdown conditions. LOS F indicates stop-and-go traffic conditions and represents unacceptable congestion and delay.

Impacts to transportation and traffic are analyzed in this Final EIS by considering the possible changes to existing traffic conditions and the capacity of area roadways from proposed increases in commuter and construction traffic. Traffic impact studies were performed and the results, together with proposed mitigation measures appropriate for each site are included in the Final EIS.

AIR QUALITY 3.6

Air quality is defined by ambient air concentrations of specific pollutants determined by the United States Environmental Protection Agency (USEPA) to be of concern related to the health and welfare of the general public and the environment and are widespread across the U.S. The primary pollutants of concern, called “criteria pollutants,” include carbon monoxide (CO), sulfur dioxide (SO2), nitrogen dioxide (NO2), ozone (O3), suspended particulate matter less than or equal to 10 microns in diameter (PM10), fine particulate matter less than or equal to 2.5 microns in diameter (PM2.5), and lead. Under the Clean Air Act (CAA), the USEPA has established National Ambient Air Quality Standards (NAAQS) for these pollutants (40 CFR 50). The NAAQS represent the maximum levels of background pollution that are considered acceptable, with an adequate margin of safety, to protect public health and welfare. Short-term standards (1-, 3-, 8-and 24-hour periods) are established for pollutants contributing to acute health effects, while long-term standards (quarterly and annual averages) are established for pollutants contributing to chronic health effects. The Kentucky Department of Environmental Protection (KDEP) has adopted the NAAQS, which are presented in Table 3-1.



Table 3-1. Ambient Air Quality Standards

Pollutant Averaging Time Primary Standard Secondary Standard

CO 8-hr 1-hr

9 ppm 35 ppm None

Lead Rolling 3-Month Average 0.15 µg/m3 Same as Primary

NO2 Annual

(arithmetic average) 53 ppb Same as Primary 1-hr 100 ppb None

PM10 24-hr 150 µg/m3 Same as Primary

PM2.5 Annual

(arithmetic average) 12.0 µg/m3 15.0 µg/m3 24-hr 35 µg/m3 Same as Primary

O3 8-hr 0.075 ppm Same as Primary

SO2 1-hour 3-hour

75 ppb -

- 0.5 ppm

Notes: ppb = parts per billion; ppm = parts per million; µg/m3 = micrograms per cubic meter. Source: USEPA 2011.

In addition to the ambient air quality standards for criteria pollutants, national standards exist for hazardous air pollutants (HAPs) which are regulated under Section 112(b) of the 1990 CAA Amendments. The National Emission Standards for Hazardous Air Pollutants regulate HAP emissions from stationary sources. HAPs emitted from mobile sources are called Mobile Source Air Toxics (MSATs); these are compounds emitted from highway vehicles and non-road equipment that are known or suspected to cause cancer or other serious health and environmental effects. In 2001, USEPA issued its first MSAT Rule, which identified 21 compounds as being HAPs that required regulation. A subset of six of these MSAT compounds were identified as having the greatest influence on health and include benzene; 1,3-butadiene; formaldehyde; acrolein; acetaldehyde; and diesel particulate matter. In February 2007, USEPA issued a second MSAT Rule, which generally supported the findings in the first rule and provided additional recommendations of compounds having the greatest impact on health. The rule also identified several engine emission certification standards that must be implemented.

Unlike the criteria pollutants, there are no NAAQS for HAPs. The primary control methodologies instituted by federal regulation for MSATs involve technological improvements for reducing their content in fuel and altering engine operating characteristics to reduce the volume of pollutants generated during combustion. MSATs would be the primary HAPs emitted by mobile sources during construction and operation of the proposed action alternatives. The equipment used during construction would likely vary in age and have a range of pollution reduction effectiveness. Construction equipment, however, would be operated intermittently over a large area and would produce negligible ambient HAPs in a localized area. Therefore, MSAT emissions are not considered further in this analysis.

A region’s air quality is influenced by many factors including the type and amount of pollutants emitted into the atmosphere, the size and topography of the air basin, and the prevailing meteorological conditions. Pollutant emissions typically refer to the amount of pollutants or pollutant precursors introduced into the atmosphere by a source or group of sources. Pollutant emissions contribute to the ambient air concentrations of criteria pollutants, either by directly affecting the pollutant concentrations measured in the ambient air or by interacting in the atmosphere to form criteria pollutants. Primary pollutants, such as CO, SO2, lead, and some particulates, are emitted directly into the atmosphere from emission sources. Secondary pollutants, such as O3, NO2, and some particulates are formed through



atmospheric chemical reactions that are influenced by meteorology, ultraviolet light, and other atmospheric processes.

The study area for the air quality analysis includes the Appalachian Intrastate Air Quality Control Region, which is defined in 40 CFR 81.191, and comprises several counties in Kentucky, including Letcher County. Air quality in the study area is considered good, with the study area designated as unclassifiable, attainment, or better than national standards for all criteria pollutants. Because the study area is in attainment for all criteria pollutants, the CAA General Conformity Rule does not apply and is not addressed in this analysis. Although a conformity analysis is not required, impacts to air quality from emissions associated with construction and operations are addressed in Chapters 4 and 5.

NOISE 3.7

Sound is a physical phenomenon consisting of minute vibrations that travel through a medium, such as air or water, and are sensed by the human ear. The perception and evaluation of sound involves three basic physical characteristics:

• Intensity – the acoustic energy, which is expressed in terms of sound pressure, in decibels (dB). • Frequency – the number of cycles per second the air vibrates, in Hertz. • Duration – the length of time the sound can be detected.

Noise is defined as unwanted or annoying sound that interferes with or disrupts normal human activities. Although continuous and extended exposure to high noise levels (e.g., through occupational exposure) can cause hearing loss, the principal human response to noise is annoyance. The response of different individuals to similar noise events is diverse and is influenced by the type of noise, perceived importance of the noise, its appropriateness in the setting, time of day, type of activity during which the noise occurs, and sensitivity of the individual.

Levels of noise are measured in units called dB. However, a number of factors affect how the human ear perceives sound: the actual level of noise, frequency, period of exposure, and fluctuations in noise levels during exposure. The human ear cannot equally perceive all pitches or frequencies and noise measurements are therefore adjusted or weighted to compensate for the human lack of sensitivity to low- and high-pitched sounds. This adjusted unit is known as the A-weighted decibel, or dBA. The A-weighted metric, de-emphasizes very low and very high pitched sound and is most often applied to noise generated by motor vehicle traffic, small boats, and aircraft. Background, or ambient, noise levels are all sounds present in an environment and are dependent upon land use. Very rural areas with little human activity would be expected to have the lowest levels of background noise, typically on the order of 15 to 20 dBA (USEPA 1971). Noise increases with increased population, as demonstrated in Table 3-2.

Table 3-2. Sound Levels Estimated by Population Density

Description Population Density

(people per square mile) Sound Level (dB) Rural (undeveloped) 20 35 Quiet suburban 60 45 Normal suburban 600 50 Urban 2,000 55 Noisy urban 6,000 60 Very noisy urban 20,000 65 Source: USEPA 1982.



INFRASTRUCTURE AND UTILITIES 3.8

Infrastructure refers to the system of public works, such as utilities, that provides the underlying framework for a community. Infrastructure components and utilities discussed in this EIS include the water supply system, wastewater system, stormwater drainage system, electrical supply facilities, natural gas system, and solid waste management facilities. Transportation infrastructure, including roadway and street systems, the movement of vehicles, and mass transit, are discussed in Section 3.5, Transportation and Traffic.

Because infrastructure and utilities systems are directly related to activities within the communities from which they draw their services, the potentially affected area includes the county where they occur. The assessment of impacts is based on comparing existing use and conditions to anticipated changes in capacity associated with the utilities. The analysis compares current use with anticipated future demands to determine potential impacts.

CULTURAL RESOURCES 3.9

Cultural resources are defined as prehistoric or historic sites, buildings, structures, objects, archaeological sites, districts, or other physical evidence of human activity that are considered important to a culture or community for scientific, traditional, or religious reasons. Cultural resources include prehistoric and historic archaeological resources, architectural resources, and TCPs.

• Archaeological resources – places where people changed the ground surface or left artifacts or other physical remains (e.g., arrowheads or bottles).

• Architectural resources – standing buildings, dams, canals, bridges, and other structures. • Traditional cultural properties – resources associated with the cultural practices and beliefs of a

living community that link that community to its past and help maintain its cultural identity. TCPs may include archaeological resources, locations of historic events, sacred areas, sources of raw materials for making tools, sacred objects, or traditional hunting and gathering areas.

Section 106 of the NHPA of 1966, as amended, and as implemented by 36 CFR 800, requires federal agencies to consider the effects of their actions on historic properties before undertaking a project that uses federal funds or is located on federal lands. A historic property is defined as any cultural resource that is included in, or eligible for inclusion in, the National Register of Historic Places (NRHP). The NRHP, administered by the National Park Service, is the official inventory of cultural resources that are significant in American history, prehistory, architecture, archaeology, engineering, and culture. The NRHP also includes National Historic Landmarks. In consideration of 36 CFR 800, federal agencies are required to consult with the State Historic Preservation Officer (SHPO), Indian Tribes, representatives of local governments, and the public in a manner appropriate to the agency planning process for the planned action (undertaking) and to the nature of the undertaking and its potential to cause effects on historic properties. The methodology for identifying, evaluating, and mitigating impacts to cultural resources has been established through federal laws and regulations including the NHPA, the Archaeological Resource Protection Act, the Native American Graves Protection and Repatriation Act, and the American Indian Religious Freedom Act.

The affected environment for cultural and traditional resources is also referred to as the area of potential effects (APE). The APE must be defined in order to assess the effects of a proposed action on a historic property. An APE is defined as the geographic area or areas within which an undertaking may directly or



indirectly cause changes in the character or use of historic properties, if any such properties exist (36 CFR 800.16[d]).

The analysis in this EIS applies the criteria of adverse effect (36 CFR 800.5) to evaluate the effects of the proposed action on any historic properties located in the APE of each action alternative. A project affects a historic property when it alters the property’s characteristics (including relevant features of its environment or use) that qualify it as significant according to National Register criteria. Adverse effects may include the following: physical destruction, damage, or alteration of all or part of the resource; alteration of the character of the surrounding environment that contributes to the resource’s qualifications for the NRHP; introduction of visual, audible, or atmospheric elements that are out of character with the resource or alter its setting; and neglect of the resource resulting in its deterioration or destruction. Impacts to traditional Native American tribal properties can be determined only through consultation with the affected Tribes. However, ground disturbance to prehistoric archaeological sites and graves has often been cited as an adverse impact.

Analysis of potential impacts to historic properties considers both direct and indirect impacts. Direct impacts may be the result of physically altering, damaging, or destroying all or part of a historic property, or neglecting the property to the extent that it deteriorates or is destroyed. Indirect impacts are those that may occur as a result of the completed project by altering characteristics of the surrounding environment through the introduction of visual or audible elements that are out of character for the period the property represents. An example of an indirect effect is increased vehicular or pedestrian traffic in the vicinity of the property.

WATER RESOURCES 3.10

Water resources include both surface and subsurface water. For the purposes of this EIS, water resources include the following topics: surface water, groundwater, water quality, wetlands, and floodplains.

Clean Water Act 3.10.1

The Clean Water Act (CWA) of 1972, as amended (33 USC §§ 1251 et seq.), is the primary federal law that protects the nation’s waters, including lakes, rivers, and coastal areas. The primary objective of the CWA is to restore and maintain the integrity of the nation’s waters. The CWA prohibits all unpermitted discharge of any pollutant into any jurisdictional waters of the U.S. The USEPA is responsible for administering the water quality requirements of the CWA. To this end, the USEPA developed pollutant-specific water quality standards (referred to as total maximum daily load [TMDL]) to identify waters for which quality is sufficiently poor and for which effluent limits would be insufficient to meet water quality standards (KDEP 2013).

In addition to the effluent restrictions, the CWA Section 404 requires a U.S. Army Corps of Engineers (USACE) issued permit for the dredging and/or filling of jurisdictional waters of the U.S. The USACE broadly defines jurisdictional waters to include navigable waters, intermittent streams, impoundments, tributary streams, and wetlands. Areas meeting the “waters of the U.S.” definition are under the jurisdiction of the USACE. Anyone proposing to conduct a project that requires a federal permit or involves dredge or fill activities that may result in a discharge to surface waters and/or waters of the U.S. is required to obtain a CWA Section 401 Water Quality Certification, verifying that the project activities will comply with water quality standards.



Rivers and Harbors Act 3.10.2

Section 10 of the Rivers and Harbors Act of 1899, as amended (33 USC § 403) regulates structures or work that would affect navigable waters of the U.S. Structures include any pier, wharf, bulkhead, etc. Work includes dredging, filling, excavation, or other modifications to navigable waters of the U.S. The USACE issues permits for work or structures in navigable waters of the U.S.

Safe Drinking Water Act 3.10.3

Congress originally passed the Safe Drinking Water Act in 1974 (42 USC §§ 300 et seq.) to protect public health by regulating the nation's public drinking water supply. The law, amended in 1986 and 1996, requires the protection of drinking water and its sources.

Surface Water 3.10.4

Lakes, ponds, impoundments, rivers, and streams compose surface water resources that are important for economic, ecological, recreational, and human health reasons.

According to the USACE, streams are drainage features that may contain perennial streams (permanent flows), intermittent streams (flows during much of the year but drying seasonally), or ephemeral streams (flows only after storm events). Ponds are open water bodies (USACE 1987).

The U.S. is divided and sub-divided into successively smaller hydrologic units, which are classified into six levels: regions, sub-regions, basins, sub-basins, watersheds and sub-watersheds. The proposed sites lie in the Ohio Region (Hydrologic Unit Code [HUC] 05); Kentucky-Licking Subregion (HUC 0510); the Kentucky River Basin (HUC 051002); and the North Kentucky River Watershed (HUC 05100201) (USEPA 2013a). Both of the sites contain surface water features including headwater intermittent and perennial streams.

Pursuant to EO 11990, Protection of Wetlands, Section 404 of the CWA, and Section 10 of the Rivers and Harbors Act of 1899, an investigation was conducted to identify potential jurisdictional waters of the U.S. A May 2011 wetland delineation of both sites investigated the proposed project area, which included the areas of expected impact by the construction associated with the proposed action, excavation needed for construction, access roads (approximately 50 feet on either side of the existing access roads), and areas previously disturbed by past mining or gas line activities. Additional wetland delineation was conducted in 2014 based on the proposed conceptual layout. The 2011 and 2014 wetland delineations included Waters of the U.S., as well as wetlands which fall under the jurisdiction of the USACE and isolated wetlands which may be exempt from USACE jurisdiction but may be protected under Kentucky’s Department of Environmental Protection. These studies supplant the usage of the National Wetland Inventory (NWI) Wetland Mapper because it is believed they are significantly more accurate; however, NWI data was used for areas not delineated during fieldwork.

Wetlands and Floodplains 3.10.5

According to USACE regulations, wetlands are those areas that are inundated or saturated by surface or groundwater at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions.

EO 11990, Protection of Wetlands, directs federal agencies to take action to minimize the destruction, loss, or degradation of wetlands on their property and mandates review of proposed actions on wetlands through procedures established by NEPA. It requires that federal agencies establish and implement



procedures to minimize development in wetlands. Wetlands provide many functions and values such as flood flow alteration, groundwater recharge/discharge, and fish and wildlife habitat.

Site specific wetland data was collected through onsite field work, aerial photographs, topographic maps, National Wetland Inventory wetland maps, and Natural Resources Conservation Service soil surveys. Based on these resources wetlands are present on the sites.

EO 11988, Floodplain Management, defines floodplains as the lowland and relatively flat areas adjoining inland waters, including at a minimum, that area subject to a 1 percent or greater chance of flooding in any given year. The area subject to a 1 percent chance of flooding is referred to as the 100-year floodplain. EO 11988 directs federal agencies to avoid construction in floodplains and establishes a process for analysis and public notice if development is unavoidable. In this EIS, the analysis of floodplains considers if any new construction is proposed within a floodplain or may impede the functions of floodplains in conveying floodwaters.

BIOLOGICAL RESOURCES 3.11

Biological resources include living, native, or naturalized plant and animal species and the habitats where they occur. Plant associations are referred to as vegetation and animal species are referred to as wildlife. Habitat can be defined as the resources and conditions present in an area that supports the existence of a plant or animal (Hall et al. 1997). Although the existence and preservation of biological resources are intrinsically valuable, these resources also provide aesthetic, recreational, and socioeconomic values to society. This analysis focuses on species or vegetation types that are important to the function of the ecosystem, of special societal importance, or are protected under federal or state law or statute.

For purposes of this EIS, these resources are divided into three major categories: vegetation, wildlife, and threatened and endangered species.

• Vegetation – includes terrestrial plant communities and the analysis will focus on vegetation types that are important to the function of the ecosystem or are protected under federal or state law.

• Wildlife – includes all vertebrate animals (i.e., mammals, reptiles, amphibians, birds, and fish) and sometimes invertebrate species or species groups such as mollusks or insects. Virtually all birds are protected under the Migratory Bird Treaty Act (MBTA). The MBTA was designed to protect migratory birds (including their eggs, nests, and feathers) and their habitats. An activity has a significant adverse effect if, over a reasonable period of time, it diminishes the capacity of a population of a migratory bird species to maintain genetic diversity, to reproduce, and to function effectively in its native ecosystem.

• Threatened and Endangered Species – include plant and animal species that are listed or proposed for listing by the USFWS under the Endangered Species Act (ESA). The federal ESA provides for the conservation of threatened and endangered species of plants and animals and the habitats where they are found. In addition, designated and proposed critical habitat for ESA-listed species will also be included in this EIS, as appropriate. This section will also address species that are listed by the State of Kentucky as threatened or endangered.



HAZARDOUS MATERIALS AND WASTE 3.12

The analysis of hazardous materials, hazardous waste, toxic substances, and contaminated sites focuses on the potential for these substances to be introduced into the environment from maintenance or during construction activities. Potentially affected areas consist of construction and operational maintenance areas. Factors considered in the analysis include the potential for increased human health risk or environmental exposure, as well as changes in the quantity and types of hazardous substances transported, stored, used, and disposed. The methodology for contaminated sites compares the proximity of proposed facility development to contaminated sites and considers the operational uses of the facilities to determine potential impacts to or from the sites.

Hazardous Materials 3.12.1

Hazardous materials are chemical substances that pose a substantial hazard to human health or the environment when improperly treated, handled, used, packaged, stored, transported or disposed. Hazardous materials are identified and regulated under the Comprehensive Environmental Response, Compensation, and Liability Act (42 USC 9601 et seq.); the Occupational Safety and Health Act (29 USC 651 et seq.); and the Emergency Planning and Community Right-to-Know Act (42 USC 11001 et seq.). Hazardous materials commonly used at Bureau facilities include petroleum and oil.

Hazardous Waste 3.12.2

The Resource Conservation and Recovery Act (40 CFR 240-280) and the Hazardous and Solid Waste Amendments of 1984 (40 CFR 260) define hazardous waste as a solid waste, or combination of wastes that due to its quantity, concentration, or physical, chemical or infectious characteristics, may cause or significantly contribute to an increase in mortality or an increase in serious irreversible or incapacitating reversible illness, or may pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, disposed of, or otherwise managed. A solid waste is a hazardous waste if it is not excluded from regulation as a hazardous waste under 40 CFR 261.4(b) and if it exhibits identified characteristics of hazardous waste or meets other specified criteria [see 40 CFR 261.3(a)].

Toxic Substances 3.12.3

The Toxic Substance Control Act addresses those chemical substances and mixtures that may present unreasonable risk of personal injury or health of the environment from their manufacturing, processing, distribution, use, or disposal. The Toxic Substance Control Act Chemical Substances Inventory lists information on more than 62,000 chemicals and substances, such as asbestos, lead-based paint, and polychlorinated biphenyls. The sites under study in this EIS are undeveloped and do not include any structures; therefore, toxic substances are not discussed further in this EIS.

CUMULATIVE IMPACT ANALYSIS 3.13

This section defines cumulative impacts and describes the approach taken in the analysis of cumulative impacts. Chapter 8, Cumulative Impacts, contains descriptions of other actions relevant to cumulative impacts, an analysis of the incremental interaction the proposed action may have with other actions, and an evaluation of the cumulative impacts potentially resulting from these interactions.

The approach taken in the analysis of cumulative impacts follows the objectives of NEPA, CEQ regulations, and CEQ guidance. Cumulative impacts are defined in 40 CFR 1508.7 as:



“the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or Non-Federal) or person undertakes such other actions.”

Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time. A cumulative impact results from the additive effect of all projects in the same geographical area. Generally, an impact can be considered cumulative if: a) effects of several actions occur in the same locale, b) effects on a particular resource are the same in nature, and c) effects are long-term in nature. The common factor key to cumulative assessment is identifying any potential temporally and/or spatially overlapping or successive effects that may significantly affect resources in the analysis areas.

ASSESSING SIGNIFICANCE 3.14

Chapters 4 and 5 present the affected environment and analysis of the potential direct and indirect effects of each alternative for each resource area described in this chapter. Chapter 8 presents the analysis of the potential cumulative effects of each alternative for each resource area. The level of significance is assessed according to NEPA implementing regulations at 40 CFR 1508.27, which requires considerations of both context and intensity.


4.0 Alternative 1-Payne Gap 4-1 July 2015

4.0 ALTERNATIVE 1 – PAYNE GAP


Potential impacts to land use are assessed by comparing the existing land uses with the changes that would occur from implementation of the proposed action, including induced effects. Impacts to land use are evaluated for significance by determining the degree to which proposed development and uses conflict with existing land use and local plans and policies. Under the proposed action, potential short-term and long-term impacts to land use would occur from construction and operation of the USP and FPC.

Growth induced impacts to land use could result from spending wages and salaries by direct and indirect employees on items such as food, housing, transportation, and medical services. This spending creates induced employment in nearly all sectors of the economy; especially service sectors (see Section 4.3, Socioeconomics and Environmental Justice).

Affected Environment 4.1.1

Land use associated with the proposed location of Alternative 1 consists primarily of forested areas. The area was previously deep mined; however, mining activities no longer occur at the site. Land use surrounding the site is also primarily forested, with small single family residential homes adjacent to the site. There are no zoning ordinances or land use classifications identified for this area (DePriest 2013). Figure 4-1 depicts existing land use associated with Alternative 1.

Environmental Consequences 4.1.2

4.1.2.1 Construction

Construction of a USP and FPC would result in changes to on-site land use. Land use associated with the Payne Gap site would be converted from forested and former mining land uses to a government/institutional land use. However, a buffer area around the USP and FPC separating it from the adjacent properties would remain and would be compatible with the adjacent land uses. Due to the lack of zoning ordinances and land use classifications, construction of the proposed USP and FPC would not result in incompatible land uses from a regulatory perspective.

4.1.2.2 Operation

Once constructed, the operation of the USP and FPC would continue as a government/institutional on-site land use with a buffer area separating it from the adjacent properties that would be compatible with adjacent land uses.

No Action Alternative 4.1.3

Under the No Action Alternative, the USP and FPC would not be constructed at the Payne Gap site and no potential land use compatibility issues with adjacent land uses would occur.


4-2 4.0 Alternative 1-Payne Gap July 2015

Figure 4-1. Payne Gap Land Use



Mitigation 4.1.4

Federal agencies are not subject to local/regional zoning or land use development regulations. However, the Bureau would take the following measures to help minimize potential adverse impacts to surrounding land uses:

• provide an open space and vegetative buffer between the USP and FPC to maintain visual compatibility with surrounding properties; and

• design and locate the facilities to reduce the visual presence of the facility from neighboring properties.

TOPOGRAPHY, GEOLOGY, AND SOILS 4.2


The topography on the Payne Gap site is typified by the mountains valleys complex associated with western Appalachian Mountains. The topography at Payne Gap has been significantly affected by strip mining activities, which historically occurred on site. According to the U.S. Geological Survey (USGS) 7.5 minute Jenkins West topographic quadrangle map, the elevation on site ranges from a low of 1,385 feet above mean sea level (AMSL) in the northwest corner of the site adjacent to the North Fork of the Kentucky River and a high of 2,965 feet AMSL on Pine Mountain in the southern portion of the site (University of Kentucky 2013a). The majority of slopes on site are very steep, well over 15 percent.

The Payne Gap site is underlain by the Breathitt Group which is composed of the Pikeville Formation and the Hyden Formation. The geology underlying the Payne Gap site is primarily Pikeville Formation (Kentucky Geological Survey [KGS] 2013).

The soils underlying the Payne Gap site are varied as a result of topography and mining disturbance, but none of the soils are listed as hydric by the Natural Resources Conservation Service (NRCS). The three most common soils at the Payne Gap site are composed of the Cloverlick-Kimper-Highsplint complex (30-65 percent slopes), the Dekalb-Gilpin-Raye complex (25-65 percent slopes), and the Kaymine, Fairpoint, and Fiveblock soil series (2 to 70 percent slopes). To a lesser degree, the following soils underlie the site; Caneyville-Renox-Bledsoe complex (50 to 80 percent slopes), Shelocta-Highsplint complex (30-65 percent slopes), and Urban land Udorthents complex (0 to 15 percent slopes) (NRCS 2013). These soils have not been designated by NRCS as prime farmland soils.


Implementation of the proposed action under Alternative 1 would result in significant impacts to topography, geology, and soils.


Development of the site would require significant excavation and fill activities to create a level pad for construction of the facilities and construction of access roads. A 2:1 fill slope and a 1:1 cut slope were used in the estimate adjacent to the building pads and roads to transition to the original topography at the Payne Gap site. More detail on the earthwork calculations can be found in Appendix B. As described in Section 2.4, Alternative 1 – Payne Gap, and Table 2-1, Estimated Site Preparation Quantities for Alternative 1 - Payne Gap, of this document, excavation activities (cut) would include 2,794,660 cubic yards (2,136,671 cubic meters) of soil material and 8,117,470 cubic yards (6,206,251 cubic meters) of



rock. The excavated soil and rock would be filled into the valleys as spoil or compacted to create a structural fill in the building pads. The amount of structural fill was estimated to be 1,716,095 cubic yards (1,312,048 cubic meters) and the amount of spoil fill would be 12,106,917 cubic yards (9,256,402 cubic meters). All excavated materials would be used on-site for structural fill or placed as spoil fill. The maximum cut (excavation) at Payne Gap would be approximately 60 meters and the maximum fill would be approximately 80 meters. Removal of bedrock would require blasting activities. Impacts resulting from these activities would include loss of productive soil, erosion, and destabilization of slopes (as a result of the cuts and fills). As a result of the excavation and fill activities, the topography of the site would change at the maximum cut from 555 meters to 495 meters (mean sea level [MSL]) in the main building area and a maximum fill from 470 meters to 550 meters MSL in the prison camp area.

The project area does not contain prime farmland soils; therefore, prime farmland soils would not be impacted and the FPPA does not apply to this site and no further coordination would be required.

4.2.2.2 Operation

Once constructed, no further impacts to topography, geology or soils are anticipated from the operation of the USP and FPC.


Under the No Action Alternative, the USP and FPC would not be constructed. Therefore, significant excavation, fill, and grading activities would not occur. As a result, there would be no impacts to topography, geology, or soils.

Mitigation 4.2.4

A soil erosion and sedimentation (E&S) plan would be prepared and approved by Kentucky Division of Water prior to construction. The E&S plan would outline the requirements for controlling erosion and sedimentation on site including BMPs. BMPs may include placement of silt fencing adjacent to surface waters and wetlands to prevent the introduction of sediment; the use of hay bales to minimize the spread of sediment off the construction site; stabilization of steep slopes, use of tree clearing plans, and stormwater control plans to manage stormwater runoff and keep it on-site during construction. Additionally, construction could be phased so that construction of the USP, FPC and ancillary facilities occurred at different times resulting in the minimization of disturbed soil by clearing only the area necessary for the current phase of construction. Re-vegetation of disturbed areas following the completion of construction would also occur to minimize the erosion of exposed soil.



This socioeconomic analysis focuses on impacts due to construction and operation of the proposed action. The assessment examines how the alternatives would affect population, employment, income, and housing characteristics in the study area. Economic impacts are defined to include direct effects, such as changes to employment and expenditures that affect the flow of dollars into the local economy and indirect effects, which result from the “ripple effect” of spending and re-spending in response to the direct effects.



Socioeconomic impacts, particularly impacts such as those being evaluated in this EIS, are often mixed: beneficial in terms of gains in jobs, expenditures, tax revenues, etc., and potentially adverse in terms of growth management issues such as demands for housing and community services.

This analysis also identifies potential environmental justice issues. Impacts to environmental justice populations are identified where high and adverse human health or environmental effects may disproportionately affect minority or low-income populations. Impacts to children would occur if there was an increased disproportionate environmental health or safety risk to children.

4.3.1.1 Population

The 2013 population of Letcher County was 24,025. Letcher County’s population decreased by approximately 3 percent between 2000 and 2010 (Table 4-1). The City of Whitesburg grew by approximately 34 percent from 2000 to 2010 and the City of Jenkins population decreased by 3 percent during the same time period. The decrease in population is likely the result of people who leave the area for better education and employment opportunities (Kentucky River Area Development District [KRADD] 2013). This trend is anticipated to continue within the county with the population decreasing by an additional 8 percent by the year 2020.

Table 4-1. Study Area Population Trends, 2000-2010

Geographic Area 2000 2010

Percent Change

2000-2010 2020 Projected

Population* Projected Percent Change 2010-2020

Whitesburg, Kentucky 1.598 2,139 33.85 --- ---

Jenkins, Kentucky 2,273 2,203 -3.08 --- ---

Letcher County, Kentucky 25,275 24,519 -2.99 22,655 -6.88

Kentucky 4,041,769 4,339,357 7.36 4,699,880 8.3

Notes: *2020 Projections only available for county and state. Source: U.S. Census Bureau 2000, U.S. Census Bureau 2010, Proximity One 2014.

4.3.1.2 Employment and Income

Letcher County’s 2013 employed civilian labor force was 7,103, out of a total civilian labor force of 8,201. Employment by industry in Letcher County is depicted in Table 4-2. The industries that employ the greatest number of people in Letcher County include educational services, and health care and social assistance (33.4 percent); agriculture, forestry, fishing and hunting, and mining (13.0 percent); and retail trade (12.7 percent). In Kentucky, the largest industry employers are educational services, and health care and social assistance (24.5 percent); manufacturing (13.7 percent); and retail trade (11.8 percent) (U.S. Census Bureau 2014a).

Letcher County is part of the largest coal producing area in eastern Kentucky. While study area jobs in the coal mining industry have been declining, positions in the health care, retail, and the secondary wood industries have increased. However, these jobs typically pay less than coal mining jobs. The study area is part of a region characterized by high unemployment and poverty rates (KRADD 2013).



Table 4-2. Study Area Employment, 2013

Industry

Letcher County, Kentucky Kentucky Number

Employed- Percent

Employed Number

Employed Percent

Employed Agriculture, forestry, fishing and hunting, and mining 922 13.0 52,348 2.8

Construction 442 6.2 111,646 6.0 Manufacturing 213 3.0 255,938 13.7 Wholesale Trade 209 2.9 49,171 13.7 Retail Trade 904 12.7 219,721 11.8 Transportation and warehousing, and utilities 360 5.1 112,005 6.0

Information 98 1.4 29,217 1.6 Finance and insurance, and real estate and rental/leasing 199 2.8 102,380 5.5

Professional, scientific, management, and administrative and waste management services

413 5.8 144,589 7.8

Educational services, health care and social assistance 2,369 33.4 456,293 24.5

Arts, entertainment, recreation, accommodation, and food services 468 6.6 159,679 8.6

Other services, except public administration 252 3.5 87,228 4.7

Public administration 254 3.6 85,390 4.6 Total 7,103 1,865,605

Source: U.S. Census Bureau 2014a.

While unemployment rates in Kentucky have decreased from a peak of 10.3 percent in 2009 to 6.5 percent in 2014, the unemployment rate in Letcher County increased dramatically from 10.6 percent in 2009 to 17.3 percent in 2013 (Table 4-3). The preliminary 2014 unemployment rate for Letcher County has decreased to 11.5 percent. The comparable rate for the U.S. was 6.3 percent (Kentucky Labor Market Information [KYLMI] 2014).

Unemployment rates in the study area are higher than the comparable rates for the state and the nation. Along with the “displaced worker,” the study area has a higher percentage of “discouraged” workers who no longer actively seek employment and are, therefore, not included in the official unemployment statistics. Therefore, the official unemployment rate in the study area is deceptively lower than actual unemployment (KRADD 2013).

Table 4-3. Study Area Percent Unemployment Rates Jurisdiction 2007 2008 2009 2010 2011 2012 2013 2014a

Letcher County, Kentucky 7.7 7.1 10.6 11.4 10.3 13.8 17.3 11.5 Kentucky 5.6 6.6 10.3 10.2 9.5 8.3 8.3 6.5

Notes: Unemployment rates are not seasonally adjusted. aAugust 2014, preliminary. Source: KYLMI 2014.

Total personal income includes net earnings by place of residence; dividends, interest, and rent received; and benefits paid by federal, state, and local governments and businesses. A larger portion of personal income in Letcher County comes from government and business benefits than for Kentucky and the U.S (U.S. Department of Commerce 2014).



Total personal income in Letcher County decreased by almost 2 percent from 2010 to 2012, while over the same time period, personal income increased by approximately 10 percent in Kentucky (Table 4-4). Between 2010 and 2012, per capita income increased in Letcher County by less than 1 percent while per capita income in Kentucky increased by 8 percent. The national per capita income was $43,735 (U.S. Department of Commerce 2014).

Table 4-4. Study Area Personal and Per Capita Income

Jurisdiction 2010 Personal Income (000)a

2012 Personal Income (000)a

Percent Change

2010-2012

2010 Per Capita Income

2012 Per Capita Income

Percent Change

2010-2012 Letcher County, Kentucky $686,680 $674,369 -1.8 $27,948 $28,155 0.7

Kentucky $143,210,961 $157,043,042 9.7 $32,947 $35,643 8.2 Notes: Not adjusted for inflation. Source: U.S. Department of Commerce 2014.

4.3.1.3 Housing

There were 11,519 housing units in Letcher County in 2013, with a total vacancy rate of approximately 19 percent (Table 4-5). The vacancy rate for owner-occupied units was 0.3 percent and vacancy rate for rental units was 1.9 percent. The comparable vacancy rates in Kentucky were higher, 12.4 percent, 2.1 percent, and 6.7 percent respectively (U.S. Census Bureau 2014b).

Table 4-5. Study Area Housing Units, 2013

Geographic Area Housing

Units

Vacant Housing

Units Percent Vacant

Homeowner Vacancy Rate

Rental Vacancy Rate

Letcher County, Kentucky 11,519 2,155 18.7 0.3 1.9 Kentucky 1,933,019 239,620 12.4 2.1 6.7 Source: U.S. Census Bureau 2014b.

4.3.1.4 Environmental Justice

For the purpose of this evaluation, minority refers to people who identified themselves in the census as Black or African American, Asian, Hawaiian or Pacific Islander, American Indian or Alaskan Native, other non-White races, or as being of Hispanic or Latino origin. Persons of Hispanic and Latino origin may be of any race (CEQ 1997). The CEQ identifies these groups as minority populations when either (1) the minority population of the affected area exceeds 50 percent or (2) the minority population percentage in the affected area is meaningfully greater than the minority population percentage in the general population or the geographic region of comparison (most often the state in which the affected area is part). The geographical unit for comparison in this analysis is Kentucky.

U.S. Census Bureau data on the racial and ethnic composition of the study area in 2013 are summarized in Table 4-6. Overall, the majority of the study area is white. Letcher County has a smaller percentage of minority and Hispanic populations than Kentucky.



Table 4-6. Study Area Percent Race and Ethnicity, 2013

Jurisdiction White Black/African

American

American Indian/Alaska

Native Asian

Native Hawaiian/Other Pacific Islander

Hispanic or Latino Origina

Whitesburg, Kentucky 97.1 1.5 0.0 0.6 0.0 1.3 Jenkins, Kentucky 98.4 0.5 0.2 0.0 0.0 0.9 Letcher County, Kentucky 98.3 0.2 0.0 0.6 0.0 0.7 Kentucky 87.8 7.9 0.2 1.2 0.0 3.2

Notes: Data presented reflects most reported race and ethnicity categories; percentages may not add to 100 percent due to rounding. *Hispanic origin may be of any race.

Source: U.S. Census Bureau 2014c.

Table 4-7 presents data on low-income families and individuals in the study area. The percentages of low-income families and individuals in Letcher County with incomes below poverty level (based on family size and composition) are greater than for Kentucky. In the study are, the City of Jenkins has the highest percentages of families and individuals with incomes below the poverty level.

Table 4-7. Study Area Percent Race and Ethnicity, 2013 Jurisdiction Families Below Poverty Level Individuals Below Poverty Level

Whitesburg, Kentucky 5.5 14.2 Jenkins, Kentucky 27.6 32.1 Letcher County, Kentucky 20.0 24.2 Kentucky 14.6 19.1

Source: U.S. Census Bureau 2014a.

4.3.1.5 Protection of Children

The percentage of children under the age of 18 is lower in Whitesburg, Jenkins, and Letcher County than for Kentucky (Table 4-8).

Table 4-8. Study Area Percent Under the Age of 18, 2013 Jurisdiction <18

Whitesburg, Kentucky 16,4 Jenkins, Kentucky 20.8 Letcher County, Kentucky 22.3 Kentucky 23.3

Source: U.S. Census Bureau 2014c.


4.3.2.1 Population

Approximately 300 new employees would be needed to operate the proposed USP and FPC. It is anticipated that some of these employees would be existing Bureau of Prisons (BOP) employees who would relocate to the area and the rest would be hired locally. Under a maximum case scenario, all 300 new personnel are assumed to move to the study area.

The BOP personnel would likely be accompanied by their families or other household members. The U.S. Census Bureau has determined that the average household size for the U.S., which is assumed to be similar to the average household size of transfer employees, is 2.58 (U.S. Census Bureau 2010). Under this assumption, approximately 774 people would be added to the study area population. This would represent 3.2 percent of the Letcher County 2013 population. This gain would help to offset some of the



recent and projected population losses in Letcher County. Alternative 1 would result in a minor beneficial impact to the study area’s short- and long-term population trends.

4.3.2.2 Employment and Income

The increase of 300 full-time positions would represent approximately 4 percent of the Letcher County 2013 civilian labor force. Study area personal income would also increase as a result of job growth. Some of the increased wage earnings would be paid to taxes, and some would be saved and invested, but most would be spent on consumer goods and services in the study area.

This spending would, in turn, “ripple” through the economy, generating additional indirect jobs and income and benefitting the study area economy. Given the rate of unemployment in the study area (11.5 percent), it would be expected that many of these indirect positions would be filled by unemployed local residents. In addition, inmates’ family members would be expected to visit, boosting visitor spending in hotels/motels and restaurants in the study area. No population in-migration to the study area would be expected as a result of indirect job growth.

The increase in construction spending would also generate direct construction jobs and indirect jobs, typically in food services and retail trade. Additional construction workers may move into the study area in response to the direct construction jobs, but these workers would most likely leave the area for other opportunities when the construction projects near completion. Further, given the study area unemployment rate, it would be expected that most of the indirect positions would be filled by unemployed study area workers. While there may be some population in-migration to the study area as a result of construction spending, it would not be expected to significantly affect population trends. Alternative 1 would result in beneficial employment and income impacts in the study area.

While the purchase of land by the Bureau for Alternative 1 would reduce property tax revenues, additional taxes would accrue to federal, state, and local governments as a result of the increase in payrolls, and operational and construction spending. It is anticipated that, on balance, the fiscal/economic impacts would be beneficial and there would be no significant adverse fiscal/economic impacts.

4.3.2.3 Housing

Alternative 1 would result in an increase of 300 full-time positions in the study area. Under a conservative scenario, all these personnel would seek housing in Letcher County at the same time. This would represent about 2.6 percent of Letcher County’s total housing units and approximately 14 percent of the vacant units. Some additional housing may be developed by the private market to support USP and FPC employees who choose to live in Letcher County. However, not all new personnel would live in Letcher County and the increase in personnel would occur over the construction period before the USP and FPC become operational, reducing any potential negative impacts to the study area’s housing market.

4.3.2.4 Environmental Justice

This EIS has identified no adverse environmental impacts that would have disproportionately high or adverse environmental effects on minority or low-income populations. Therefore, Alternative 1 would not result in significant adverse impacts to environmental justice communities.



4.3.2.5 Protection of Children

This EIS had identified no adverse environmental impacts that would result in disproportionate health or safety risks to children. Therefore, Alternative 1 would not result in significant adverse impacts to the health or safety of children.


Under the No Action Alternative, the USP and FPC would not be constructed. As a result, there would be no potential for beneficial socioeconomic impacts such as new jobs and potential growth of business within the region. This could result in the sustained poor economic climate in the region. The No Action Alternative would not result in adverse impacts to environmental justice communities or children.

Mitigation 4.3.4

No adverse impacts to socioeconomics, environmental justice populations, or children would be expected; therefore, no mitigation would be warranted. Beneficial impacts would be anticipated and the community is prepared to accommodate growth.



4.4.1.1 Police

Law enforcement servicing the area around and including the Payne Gap site is serviced by the Fleming Neon Police Department, Jenkins Police Department, Letcher County Sheriff, and Kentucky State Police. The Fleming Neon Police Department has three full-time employees consisting of one police chief and two police officers, as well as one volunteer that operate out of a single station in Fleming Neon. The station has three squad cars and provides service 24-hours per day, seven days a week (Fleming Neon Police Department 2013).

The Jenkins Police Department has six full-time personnel consisting of one police chief, four police officers, and the Public Safety Director. The department is currently short staffed by one person. The police department operates out of one station in Jenkins. The station operates eight squad cars and provides 24-hour coverage (Jenkins Police Department 2013).

The Letcher County Sheriff’s office is comprised of 13full-time employees including 10 deputies and 3 dispatchers. The office operates 10 squad cars and is headquartered in Whitesburg. The office provides 24-hour coverage, seven days per week (Letcher County Sheriff 2013).

The Kentucky State Police for Letcher County operates out of the Hazard Post and covers a total of five counties including Letcher County. The Hazard Post currently has 39 state troopers, 18 dispatchers, 3 clerks, 1 custodian, 1 criminal analyst, and 1 arson specialist. They operate 39 squad cars, and have 8-10 spare squad cars available in the event one is needed (Kentucky State Police 2013).

4.4.1.2 Fire

Fire departments that provide emergency services for the Payne Gap area include the Fleming Neon Fire Department, Jenkins Volunteer Fire Station, and Whitesburg Fire and Rescue. The Fleming Neon Fire Department has approximately 36 firefighters and emergency medical technicians (EMTs) at the Fleming Neon Volunteer Fire Station. Sixteen are paid, full-time employees and 20 are volunteers. The station has



seven paramedics and eight EMTs. The department has a single station in Fleming Neon and a substation in Whitesburg. The Fleming Neon Station has two fire engines, 10 ambulances, 1 tanker truck, 1rescue truck, 1 dive trailer (for underwater rescue) and 1 all-terrain vehicle for search and rescue operations. Four ambulances run during the day and 1 run at night. Firefighters run 3 crews during the day and 1 crew at night. The station has mutual aid agreements with all the towns in Letcher County (Fleming Neon Fire Department 2013).

The Jenkins Volunteer Fire Station consists of between 25-28 firefighters and three administrative personnel with two stations in Jenkins. All firefighters are volunteers and 5 of the firefighters are also EMTs. Equipment associated with the stations includes 2 fire engines, an 85-foot tower truck, a 65-foot ladder truck, a 2,500 gallon tanker truck, 1 heavy rescue truck, and 1 vehicle for personnel transport. The Jenkins Volunteer Fire Station has mutual aid agreements with all other stations in Letcher County (Jenkins Volunteer Fire Station 2013).

4.4.1.3 Healthcare

Appalachian Regional Healthcare (ARH) serves over 350,000 residents in eastern Kentucky and southern West Virginia. Their operations in Letcher County, Kentucky include the Whitesburg ARH Hospital, ARH Clinic, Jenkins ARH Clinic, Neon ARH Clinic, ARH Cardiology Clinic and Home Health Agency. Whitesburg ARH completed an $11 million dollar renovation project in 2011 that included a 15,000 square foot addition to the facility that houses surgical, obstetric, and newborn patients. Renovations to the existing space included a complete remodel of the third floor to include six Intensive Care Unit beds and 20 private patient rooms. Whitesburg ARH Hospital provides 24-hour emergency service for both adult and pediatric patients and has an on-site heliport for receiving and transferring patients. Whitesburg ARH is an acute care hospital that covers internal medicine, family practice, pediatrics, general surgery, advanced laparoscopic surgery, obstetrics and gynecology, cardiology, pulmonology, radiology and emergency services.

Mountain Comprehensive Health Corporation located in Whitesburg, Kentucky offers dental, family and internal medicine, pediatrics, cardiology, pulmonology, and obstetrics and gynecological services, as well as a rehabilitation program. Mountain Comprehensive Health Corporation also has a full service laboratory.

4.4.1.4 Schools

The schools in Letcher County are administered by the Letcher County School District. There are five elementary schools, three middle schools, and one high school. Table 4-9 depicts the names of the schools, the grades they serve, the number of students enrolled for the 2014-2015 school year and the actual capacity of each school.



Table 4-9. Letcher County Schools Enrollment and Capacity for 2014-2015 School Grades Number of Students Capacity

Arlie Boggs Elementary K-8 127 248 Cowan Elementary K-8 423 440 Fleming Neon Middle School 6-8 202 352 Letcher County Elementary K-5 372 418 Letcher County Middle School 6-8 158 225 Letcher County Central High School 9-12 929 1033 West Whitesburg Elementary School K-5 392 440 Whitesburg Middle School 6-8 170 225 Martha Jane Potter Elementary K-5 438 425 Source: Wagoner 2014.


4.4.2.1 Police

The law enforcement groups that have jurisdiction over the area where the Payne Gap site is located would be able to provide assistance in the event of an emergency situation at the USP that required assistance beyond the capabilities of the USP. The individual law enforcement agencies have stated they would be willing to discuss the development of a Memorandum of Understanding (MOU) with the Bureau to provide these services. Law enforcement indicated this would not result in impacts to their services or require the hiring of additional staff; therefore, the proposed action would have no impact to law enforcement.

4.4.2.2 Fire

Fire departments that would provide emergency services for the area where the Payne Gap site is located would be able to provide assistance to the USP and FPC in the event there was an incident that was beyond the capabilities of the USP and FPC. The individual fire departments have indicated they would be willing to discuss the development of a MOU with the Bureau to provide these services. The fire departments indicated that this would not result in impacts to their services or require the hiring of additional staff; therefore, the proposed action would have no impact to emergency services.

4.4.2.3 Healthcare

Healthcare facilities are located within close proximity to the Payne Gap site and would be able to accommodate inmates at the proposed USP and FPC if needed. Discussions with ARH indicate they have staff familiar with accommodating inmates and the necessary security requirements that would need to be implemented to bring an inmate into a healthcare facility. ARH indicated this would not be a problem and they would be able to accommodate the facility if an inmate would require care outside of the USP or FPC. ARH also indicated they would be willing to work with the Bureau to develop a MOU (Sparkman 2014).

4.4.2.4 Schools

It is assumed that approximately 300 new employees would be needed to operate the proposed USP and FPC. It is anticipated that some of these employees would be existing Bureau employees that would relocate to the area. Bureau employees relocating to operate the facility may not all reside within the immediate area (Whitesburg, Jenkins, or Letcher County). It would be anticipated that some would reside



outside of the immediate area. With the exception of Martha Jane Potter Elementary school, all the schools within Letcher County School District have sufficient capacity to accept new students.


Under the No Action Alternative, the USP and FPC would not be constructed. Community facilities and services would continue to operate under existing conditions. Law enforcement, emergency services, and healthcare providers within the area would not be asked to support the facility in emergency situations; therefore, no impacts to these services would occur.

Mitigation 4.4.4

Impacts to community facilities and services would not occur; therefore, no mitigation would be warranted.


The analysis of transportation and traffic describes both personal and public vehicle movement throughout a road and highway network. The study area for transportation and traffic includes the road and highway networks that surround and provide access to the proposed site parcels.

Rural collector roads are divided into major and minor collector roads. Major collector roads are used for inter-county travel or for carrying vehicles to routes of higher classification (principal arterials and minor arterials) (Division of Planning 2011). Minor collector roads collect traffic from local roads and carry it to major collector roads, minor arterial roads, and/or principal arterials. Rural principal arterials are those roadways that have continuous routes that lend themselves to statewide or interstate travel and typically have limited access (Division of Planning 2011).


The Payne Gap site is located approximately 7.5 miles to the east of Whitesburg, Kentucky. This project alternative would be constructed to the south of U.S. Route 119, to the east of Bottom Fork Road (KY 3406), and to the west of Talman Drive. In the project vicinity, U.S. Route 119 is designated as a rural principal arterial1 on the Kentucky Transportation Cabinet’s (KYTC’s) statewide map of roadway functional classifications (KYTC 2014a). KYTC traffic count station 272 is located on U.S. Route 119 approximately 0.5 miles west of the site. The year 2010 Annual Average Daily Traffic traffic volume at this location was 6,778 vehicles per day (KYTC 2014b). The site has several access options. These include driveways onto Bottom Fork Road, U.S. Route 119, Talman Drive, and a connection to Fork Drive, which is an existing roadway that extends southward from U.S. Route 119.

As defined by KYTC, rural principal arterials “comprise a system of continuous, connected, rural routes having trip length and density suitable for statewide or interstate travel. They provide for movement between all urban areas with a population of 50,000 or more and most urban areas with a population of at least 25,000” (KYTC 2014a).

A traffic impact study for the Payne Gap site was prepared and received concurrence from the KYTC Central Office on April 30, 2015 and from the KYTC District 12 Office on May 5, 2015. The study identified that U.S. Route 119 is currently operating at LOS A during both am and pm peak periods (7:00 a.m.-9:00 a.m. and 3:00 p.m.-5:00 p.m. respectively) (Parsons 2015).





Implementation of either action alternative would involve temporary traffic impacts resulting from construction activities. The following types of additional trips are expected to be added to the highway network:

• Construction worker commuting trips • Trips involving the delivery and removal of construction equipment and materials • Trips involving the removal of demolition debris and/or excess fill material

These trips would be temporary, and would not continue after the completion of project construction. Whereas construction worker commuter trips are expected to be concentrated during the traditional peak commuting periods, other trips would likely be dispersed throughout the typical working day. Trucks would be used to deliver/remove construction equipment and materials and to remove demolition debris and/or excess fill material during construction. Because of their size and weight, trucks have a relatively greater impact on street capacity and pavement conditions, as compared to passenger cars. Given the temporary nature of construction truck traffic, and given that trucks are not expected to be concentrated in peak commuting periods, the potential impact to roadway capacity would be less than significant. The potential impact to roadway wear and tear would be avoided or reduced to a less than significant level with the implementation of mitigation described below in Section 4.5.4, Mitigation. With this measure, the addition of construction-related trips is not expected to result in a significant traffic-related impact.

4.5.2.2 Operation

Following construction, the proposed facility would add traffic to the surrounding street network on a recurring basis. This traffic increase would include employee commuting trips, plus additional trips (such as the transfer of inmates, inmate visitors, delivery of supplies and equipment, etc.) that would not necessarily coincide with peak commuting periods. As discussed in Section 1.6, Proposed Action, the proposed facility would have a staff of 300 full-time employees. The proposed action’s traffic generation was estimated using trip generation rates published in the Institute of Transportation Engineers’ (ITE) Trip Generation Manual (ITE 2012). Table 4-10 presents peak hour traffic generation. As shown in this table, the proposed facility would add approximately 156 trips during the morning peak hour and 204 during the afternoon peak hour.

Table 4-10. Estimated Peak Hour Trip Generation AM Peak Hour Trips PM Peak Hour Trips

In Out Total In Out Total 97 59 156 55 149 204

Note:(a) Land use and trip rates from ITE Trip Generation Manual, 9th Edition (ITE 2012) for Land Use 571 (Prison). Source: Parsons 2015.

It is anticipated that a higher number of trips are expected to be generated in the p.m. peak period based on the previous studies performed and documented in the ITE Trip Generation Manual of traffic patterns associated with a federal correctional facility (Parsons 2015). Additional trips to/from the site are expected to occur during off-peak hour commuting periods. These off-peak trips may include the transfer of inmates, inmate visitors, and delivery of supplies and equipment. Based on the low volumes on KY 588, there is no anticipated impact associated with these off-peak trips.



The traffic impact analysis determined that with the additional peak hour trips U.S. Route 119 would continue to operate at a LOS A during both a.m. and p.m. peak periods. The study also found that the intersection of U.S. Route 119 and the entrance to the facility would operate at LOS A for westbound traffic during both a.m. and p.m. peak periods and LOS B for northbound traffic during the same peak periods. Appendix F contains the traffic impact study and Appendix A contains the email communications with KYTC regarding the traffic impact study.

These potential impacts would be avoided or reduced to a less than significant level with the implementation of mitigation described below in Section 4.5.4, Mitigation.


Under the No Action Alternative, the USP and FPC would not be constructed and increases in traffic to area roadways would not occur. It is anticipated that traffic would remain close to existing conditions; therefore, no impacts to transportation or traffic would occur.

Mitigation 4.5.4

Although there are no significant impacts to traffic outlined in the traffic impact study, KYTC has recommended that consideration be given to constructing a left turn lane on U.S. Route 119 for vehicles traveling westbound. The left turn lane would minimize the potential for rear-end vehicle collisions.

AIR QUALITY 4.6


The air quality analysis evaluates projected future emissions, including construction and operations. Air quality impacts would be significant if emissions associated with the proposed action would: 1) increase ambient air pollution concentrations above the NAAQS, 2) impair visibility within federally mandated Prevention of Significant Deterioration Class I areas, 3) result in the potential for any stationary source to be considered a major source of emissions if total emissions of any pollutant subject to regulation under the CAA is greater than 250 tons per year (TPY) for attainment areas, or 4) for mobile source emissions, result in an increase in emissions to exceed 250 TPY for any pollutant. The air quality assumptions and calculations are provided in Appendix C, Air Emission Calculations.

Pollutants considered in this analysis include the criteria pollutants. Airborne emissions of lead are not considered because there would be no sources of airborne lead associated with the proposed action with the exception of the firing range, which would be indoors.

For criteria pollutant emissions, 250 TPY per pollutant was used as a comparative analysis threshold. This value is used by the USEPA in their New Source Review standards as an indicator for impact analysis for listed new major stationary sources in attainment areas. No similar regulatory threshold is available for mobile source emissions, which are the primary sources for the construction phases, and also a component of operational emissions for the proposed action. Lacking any mobile source emissions thresholds, the 250 TPY major stationary source threshold was used to equitably assess and compare mobile source emissions.

Pollutants would be generated by numerous sources, including diesel exhaust from construction equipment, gasoline exhaust from the driving tracks and operations such as generators and boilers. In general, volatile organic compound (VOC), carbon monoxide (CO), nitrous oxides (NOx), and sulfur dioxide (SO2) emissions would be primarily generated by diesel-fueled heavy equipment operating in



construction areas. Particulate matter (PM) emissions, in the form of PM10 and PM2.5 would be primarily due to fugitive dust created by land disturbance activities, which would include land clearing; soil excavation, cutting, and filling; trenching; and grading. The fugitive dust emission factor for PM10, which is used as part of the PM2.5 calculation (Midwest Research Institute 2005), is assumed to include the effects of typical control measures such as routine site watering and other measures for dust control. A dust control effectiveness of 50 percent is assumed, based on the estimated control effectiveness of watering (Western Governors’ Association 2006). Other sources of emissions include diesel emissions from heavy construction equipment. Refer to Appendix C, Air Emission Calculations, for further discussion of the technical approach and assumptions.

Air emissions were analyzed, where applicable, based on proposed construction activities and operational emissions that would occur during full operation.

Under the CAA, motor vehicles and construction equipment are exempt from air permitting requirements. Since the emissions from these sources associated with the proposed action would occur in areas that are in attainment of the NAAQS for all criteria pollutants, the General Conformity Rule is not applicable. Nonetheless, NEPA and its implementing regulations require analysis of the significance of air quality impacts from these sources as well as non-major stationary sources. However, neither NEPA nor its implementing regulations have established criteria for determining the significance of air quality impacts from such sources in CAA attainment areas.

As noted above, the General Conformity Rule is not applicable to these mobile sources and minor (i.e., non-major) stationary sources in attainment areas. Therefore, the analysis of construction and operational incremental emissions from these sources in attainment areas and the significance criteria selected (250 TPY) are solely for the purpose of informing the public and decision makers about the relative air quality impacts from the Proposed Action under NEPA requirements.


The results of the air emissions analysis show that construction and operational emissions would remain well below the significance thresholds and would not have a significant impact on the local or regional air quality. A summary of the analysis is presented below and the complete analysis is provided in Appendix C, Air Emission Calculations.


Direct impacts from emissions from construction would include combustion emissions from fossil fuel-powered equipment and fugitive dust emissions (PM10 and PM2.5) during clearing, demolition activities, earth moving activities, and operation of equipment on bare soil. Table 4-11 presents estimates for the primary construction activities that would utilize heavy duty diesel equipment for the Payne Gap site.

Table 4-11. Construction Emission Estimates for Payne Gap Site

Site Year VOC Tons

CO Tons

NOx Tons

SO2 Tons

PM10 Tons

PM2.5 Tons

Payne Gap 1 7.80 32.35 108.53 1.90 217.59 27.05 Payne Gap 2 7.80 32.35 108.53 1.90 147.09 20.00

Fugitive dust from land disturbance activities would be the primary source of emissions during construction, with most of the emissions occurring during Year 1. PM10 emissions are estimated using wetting and other typical reduction practices to reduce dust release by 50 percent. PM10 emissions are



predicted to be greatest in Year 1 at the Payne Gap site, at 217.59 TPY. These emissions, however, would remain well below the significance threshold of 250 TPY. Construction emissions would not have direct or indirect significant impacts on the region’s air quality.

Direct impacts to air quality may also include emissions from the burning of construction debris, if such an activity were undertaken during construction. Vegetative debris and/or demolition and construction materials would be disposed in accordance with all laws and regulations. Should open burning be necessary, it would be conducted in accordance with Title 401 of the Kentucky Administrative Regulations, Section 63 (401 KAR 63:005) Open Burning.

4.6.2.2 Operations

Table 4-12 presents the annual emissions based on the site being fully operational. Operational emissions would be the same regardless of the location selected. Stationary sources operating onsite include two 2000-kilowatt diesel-powered emergency generators and three boilers to provide heat and hot water for the site. The boilers have been estimated at 15 MMBtu/hr. One of the boilers would serve as a backup, so air emission calculations evaluated use of two boilers. All of these stationary sources would require an air permit and be regulated by the KDEP, Division for Air Quality. Analysis of permit requirements based on the final stationary source(s) type and design would be performed as design requirements are more fully delineated. This would ensure regulatory permit compliance and that all requisite source registrations would be submitted.

In addition to stationary sources, the emissions from staff commuting to and from work have been estimated at 300 employees and working 365 days per year. The round trip was estimated at 40 miles because of the rural locations that have been selected for analysis.

Table 4-12. Estimated Annual Operational Emissions

Source VOC

Tons/Year CO

Tons/year NOx

Tons/ Year SO2

Tons/Year PM10

Tons/Year PM2.5

Tons/Year Generators 0.25 2.15 5.09 0.00 0.27 0.27 Boilers 0.26 3.80 15.2 0.16 0.76 0.19 Staff Vehicles 0.19 23.38 1.07 0.02 0.12 0.11

Total 0.70 29.33 21.36 0.18 1.16 0.58

All of the criteria pollutant emissions remain well below the significance threshold of 250 TPY. Based on the emission estimates, operation of the BOP complex would not have direct or indirect significant impacts on the local or regional air quality.


Under the No Action alternative, the USP and FPC would not be constructed in Letcher County. The No Action Alternative would not result in emissions of any air pollutants. Therefore, there would be no impact to regional air quality.

Mitigation 4.6.4

Best management practices would be implemented to reduce air emissions. They may include, but are not limited to:



• Impacts to air quality (PM10 emissions) from fugitive dust would be minimized by periodic wetting during construction activities when clearing, excavation, filling and grading activities would occur.

• Utilization of alternatively fueled equipment. • Utilization of other emission controls that are applicable to the equipment being used on-site. • Reduction of idling time of equipment and construction vehicles.

NOISE 4.7


The Occupational Safety and Health Administration (OSHA) regulates noise impacts to workers and sets forth thresholds for a safe work environment. OSHA has set permissible noise exposure limits (codified in 29 CFR 1910.95[b]). Based on these limits, an employee should not be subjected to continuous noise exceeding 90 dBA for durations lasting more than 8 hours per day (Table 4-13). As the level increases, the allowed duration of noise decreases. The maximum limit is 115 dBA for duration of 15 minutes or less. OSHA standards are the best documented requirements in regards to long-term human noise exposure. In addition, OSHA standards state that exposure to impulsive or impact noise (loud, short duration sounds) is not to exceed 140 dB peak sound pressure level (OSHA 2013).

Table 4-13. OSHA Permissible Noise Exposures Duration per Day (hours) Sound Level (dBA)

8 90 6 92 4 95 3 97 2 100

1.5 102 1 105

0.5 110 0.25 or less 115

Source: 29 CFR 1910.95(b).

The Payne Gap site is located in a rural area with minimal noise. Areas of the site located immediately adjacent to U.S. Route 119 would experience some noise from traffic traveling through the area. There is nothing located on the site that currently generates noise.



Construction activities associated with the proposed action would result in temporary, short-term increases in noise levels. Noise associated with construction equipment and vehicles, as well as blasting activities to remove bedrock, would occur during site preparation and construction.

As stated in Section 3.6.1, Affected Environment, OSHA standards (29 CFR 1910.95) state that employees should not be subjected to continuous noise exceeding 90 dBA for durations lasting more than 8 hours per day. For the purposes of this analysis, noise at a sensitive receptor above the level for a residential district, 55 dBA, is noted for impacts, and noise emissions exceeding 90 dBA for more than 8 hours per day at a sensitive receptor location would be considered to have significant adverse impacts.



A noise sensitive receptor is defined as a location or facility where people involved in indoor or outdoor activities may be subject to stress or considerable interference from noise. Such locations or facilities often include residential dwellings, hospitals, nursing homes, educational facilities, and libraries. Sensitive noise receptors may also include supporting habitat for certain wildlife species or noise sensitive cultural practices.

The proposed action would generate noise during the construction phases of the USP and FPC. Phases of construction that would generate noise include: land clearing and excavations, pile driving, foundation and capping, erection of structural materials, and construction of exterior walls. Construction activities that would impact noise levels include noise from construction equipment operating at the site, construction/delivery vehicles traveling to and from the site, and pile driving activities required for placement of deep pile foundations. Noise levels at a given receptor location would depend on the type and number of pieces of construction equipment being operated and the receptor’s distance from the construction site. Construction related noise emissions are listed in Table 4-14 and can range from 74 to 101 dBA when measured 50 feet from the respective piece of equipment.

Table 4-14. Airborne Construction Related Noise Emissionsyu

Equipment Description Actual Measured Lmax at

50 feet (dBA) Flat Bed Truck 74 Welder/Torch 74 Man Lift 75 Dump Truck 76 Backhoe 78 Compressor (air) 78 Concrete Mixer Truck 79 Drill Rig Truck 79 Front End Loader 79 Rivet Buster/Chipping Gun 79 Ventilation Fan 79 Drum Mixer 80 Vibratory Concrete Mixer 80 Concrete Pump Truck 81 Crane 81 Generator 81 Pumps 81 Dozer 82 Boring Jack Power Unit 83 Warning Horn 83 Auger Drill Rig 84 Scraper 84 Pneumatic Tools 85 Vacuum Excavator 85 Vibrating Hopper 87 Jackhammer 89 Concrete Saw 90 Mounted Impact Hammer (hoe ram) 90 Sheers (on backhoe) 96 Impact Pile Driver 101 Vibratory Pile Driver 101

Source: Federal Highway Administration 2006.



Small increases in noise levels would be expected as a result of the operation of delivery trucks and other construction vehicles. However, larger increases in noise levels would result if pile driving activities are necessary. Increased noise levels would be greatest during the early stages of each construction phase, although these periods would be of relatively short duration. However, under the worst case scenario during pile driving, there would be periods during construction when noise would range from 101 dBA at 50 feet from the equipment to 89 dBA at 200 feet from the equipment. The 200-foot radius from the equipment would encompass primarily rural undeveloped areas, depending on the location of the pile driving equipment at any given time on the Payne Gap site. When compared to the existing noise conditions at the Payne Gap site (35 dBA) and the OSHA noise thresholds for workers, the pile driving activities would result in significant short-term impacts to noise receptors located within 200 feet of the pile driving equipment location at the construction site, which would vary as the foundation piles would be driven throughout the foundation footprint. Moderate noise impacts would extend up to 1.5 miles from the construction site, as this is the distance at which noise levels would attenuate down to 55–60 dBA.

In conclusion, temporary and short-term noise disturbance would occur during construction; however, implementation of noise attenuation measures described below would reduce potential disturbance from noise. Therefore, implementation of Alternative 1 would have no significant impacts to sensitive noise receptors from noise.

4.7.2.2 Operation

The operation of the proposed USP and FPC, once construction is completed, is not expected to significantly increase ambient noise levels.


Under the No Action Alternative, the USP and FPC would not be constructed and no increases in noise as a result of construction or operation would occur. It is anticipated that the site would remain undeveloped; therefore, no increases in noise that my present impacts to nearby noise receptors would occur.

Mitigation 4.7.4

To minimize the impact to noise receptors during the operation of the pile driving equipment, a variety of measures could be taken, including but not limited to:

• Using noise bellows systems to provide further noise attenuation. • Performing the work during daytime hours. • Scheduling the louder construction activities for less intrusive times (mid-morning to mid-

afternoon).



4.8.1.1 Potable Water

Letcher County Water and Sewer District (LWSD) would provide service to the Payne Gap site. LWSD has been extending service in the area which includes an area along U.S. Route 119, adjacent to the Payne Gap site. The water main at this location is 8 inches in diameter and has water pressure near the connection point of approximately 110 pounds per square inch (psi). Potable water would be provided by



LWSD via a connection approximately 3.5 miles away from the Payne Gap site (Cardno 2014a). The existing permitted capacity for water is 4,000,000 gallons per day with 2,000,000 gallons per day currently being used.

4.8.1.2 Waste Water

Sanitary sewer service would be provided by the City of Jenkins and treated at the Jenkins Waste Water Treatment Plant (WWTP). The nearest connection point is located at the Gateway Industrial Park in Jenkins, approximately 1.5 miles east of the Payne Gap site (Figure 4-2). The facility was designed to treat approximately 600,000 gallons per day and currently treats approximately 400,000 gallons per day (KRADD 2013).

4.8.1.3 Natural Gas

There is one gas well on site, located in the northeast corner of the property. In addition there is an above ground 16-inch high pressure transmission line running directly through the property. The gas well and transmission line are both owned by EQT (Cardno 2014a).

4.8.1.4 Electricity

American Electric Power (AEP) lines extend along U.S. Route 119 in the vicinity of the Payne Gap site and would be able to provide electricity to the Payne Gap site (Cardno 2014a).

4.8.1.5 Telecommunications

Windstream provides telecommunications service in the area of Payne Gap with fiber and copper cables in the vicinity of U.S. Route 119. Windstream has sufficient capacity in this area to provide adequate service to the proposed Bureau facility (Cardno 2014a).

Draft Environmental Impact Statement for USP and FPC Letcher County, Kentucky

4-22 4.0 Environmental Consequences July 2015

Figure 4-2. Payne Gap Existing Utilities



4.8.1.6 Solid Waste

Solid waste generated within Letcher County is disposed of at the Laurel Ridge Landfill in London, Kentucky, approximately 90 miles west of Whitesburg, Kentucky (Crouch 2014). The Laurel Ridge Landfill has a maximum annual limit of 350,000 tons. The landfill currently receives approximately 320,000 tons annually. Based on their current capacity, the landfill has a 30-year life expectancy.



The USP and FPC are anticipated to require 214 gallons per day per inmate. Based on an anticipated inmate population of 1,200 a total of 258,000 gallons per day would be required under the proposed action. Additionally, the utility plant, warehouses, and training building would require approximately 6,160 gallons per day. Based on the available permitted capacity of 4,000,000 gallons per day and current usage of approximately 2,000,000 gallons per day the additional usage by the USP, FPC and ancillary facilities would not result in impacts to the water supply.

4.8.2.2 Waste Water

Average waste water generated by the USP, FPC and ancillary facilities is anticipated to be 224,000 gallons per day. This would result in the City of Jenkins WWTP exceeding their design capacity of 600,000 gallons per day by approximately 24,000 gallons per day. As a result, the proposed action would result in significant impacts to the City of Jenkins WWTP.

4.8.2.3 Natural Gas

Implementation of the proposed action at the Payne Gap site would result in the closure and abandonment of a gas well and relocation of an above ground natural gas pipeline. Closure of the gas well would result in lost natural gas production and profit to the owner of the well, EQT. Additionally, the relocation of the natural gas pipeline would result in a loss of transmission and resulting profit to EQT during the relocation process. EQT would also have expend resources to relocate the gas line, as well as acquire right-of-way and permits to complete the relocation. Due to the location of the Jefferson National Forest to the south, the relocation of the line is limited to moving it to the north of its current location. As a result of the implementation of the proposed action at Payne Gap, significant impacts to natural gas infrastructure would occur.

4.8.2.4 Electricity

Coordination with the service provider, AEP, has indicated they have ample capacity to provide service to the facility. AEP would extend overhead lines to a pre-determined handoff point to the secure facility and the Bureau would extend the service on-site to the needed facilities (Cardno 2014a). There would be no charge to extend the overhead lines to the handoff point and no issues with capacity; therefore, no adverse impacts to electrical capacity would occur as a result of the proposed action.


Windstream has indicated that they have sufficient capacity to meet the needs of the proposed USP, FPC, and ancillary facilities at the Payne Gap site. The Bureau would be responsible for connecting the fiber cables at a splice location adjacent to the Payne Gap site, as well as connection of copper cables at the Gateway Industrial Park in Jenkins. Connection costs would be approximately $35,000.



4.8.2.6 Solid Waste

It is anticipated that inmates would generate 4 pounds of solid waste per day or 1,460 pounds per year. With an estimated 1,200 inmates that would result in 4,800 pounds per day or 1,752,000 pounds per year (876 tons per year). Under the proposed action, the solid waste generated at the facility would increase the current tons per year taken to the Laurel Ridge Landfill from 320,000 to 320,876 tons per year. This increase would not result in the landfill going over there current yearly maximum intake of solid waste; therefore, there would be no adverse impacts to the Laurel Ridge Landfill.


Under the No Action Alternative, the USP and FPC would not be constructed and the Payne Gap site is anticipated to remain undeveloped. If the Payne Gap site is not developed, there would be no requirement for additional utilities; therefore, it is anticipated that utility usage would remain similar to existing usage.

Mitigation 4.8.4

Mitigation for impacts to wastewater treatment as a result of the implementation of the proposed action at the Payne Gap site would require either the upgrade of the existing City of Jenkins WWTP or the construction of a new WWTP closer to the Payne Gap site. Coordination with the City of Jenkins indicates there are two options to provide waste water treatment to the Payne Gap site (Cardno 2014a). The Bureau would have to pay for these mitigation measures which would be approximately $3,800,000.

Mitigation of impacts to natural gas infrastructure at the Payne Gap site would require the Bureau to pay for the closure of the gas well and relocation of the natural gas pipeline. The gas well would require closure at a cost of $850,000. Additionally, the above ground gas line would require relocation off-site. It is anticipated that 9,000 linear feet of gas line would need to be relocated at a cost of $455 per linear foot (Cardno 2014a). This would result in a total cost for relocation of approximately $4,095,000. The Bureau would also have to pay for a connection fee of $110,000. In addition to the relocation costs, it would take a minimum of 2-years to design, permit and install this pressure main. The Bureau would also be required to assess the impacts of both the removal of the gas line and the relocation of the gas line, which could result in additional studies and mitigation (i.e., wetland delineation, cultural resource studies, threatened and endangered species).


An APE was defined to take into consideration both potential direct and indirect effects to cultural resources from implementation of the proposed action. The APE for Alternative 1 includes the 753-acre (305-hectare) Payne Gap site and adjacent areas to the north (Figure 4-3). The APE extends beyond the north boundary of the Payne Gap site because of the potential for visual effects to any historic properties that may be present within the viewshed of the proposed federal correctional facility’s one- to four-story buildings. Effects to archaeological resources, however, would be limited to the 300-acre (121-hectare) area within the APE where construction (direct ground disturbance) would occur.


4.0 Environmental Consequences 4-25 July 2015

Figure 4-3. Payne Gap Architectural Resources




4.9.1.1 Archaeological Resources

The Payne Gap site has been subject to previous mining activities; however, the mining activities did not appear to extend to the entire site. Therefore, a Phase I Archaeological Survey was conducted in August 2011 and an additional Phase I archaeological investigation was conducted in August 2014. The surveys conducted pedestrian traversal of transects across areas that were not too steep, surface survey in areas of high ground surface visibility, search of rocky outcrops for rockshelters and other cultural features, and limited subsurface testing of flatter ridgetop, ridgeline, and slope terraces. In addition, background research indicated that no previously identified archaeological sites were present at the proposed Payne Gap site.

A total of 40 shovel test pits were excavated within the APE during both Phase I surveys. No artifacts and no prehistoric or historic archaeological sites eligible for listing on the NRHP were discovered. As a result of both surveys, no further work was recommended at the proposed Payne Gap site. Concurrence on the 2011 survey recommendation was received from the SHPO on January 24, 2012, and concurrence on the 2014 survey recommendation was received on December 22, 2014 (Appendix A, Agency Coordination).

4.9.1.2 Traditional Cultural Properties

Under Section 106 of the NHPA, a federal agency is required to give consideration to issues of traditional religious or cultural areas concerning Native American groups. No TCPs have been identified within the project APE based on there being no federally recognized tribes within Kentucky.

4.9.1.3 Architectural Resources

Architectural surveys were conducted to identify historic properties in the Payne Gap site APE. The initial reconnaissance survey of the APE was conducted in May 2011. The survey recommended four architectural resources for further investigation to determine their eligibility for inclusion in the NRHP. Other architectural resources located in the APE were not associated with significant historical or architectural contexts of Letcher County and/or were in poor condition; therefore, they were not recommended for further work (TEC, Inc. 2011a). The Kentucky Heritage Council (KHC), the Kentucky SHPO, concurred with the reconnaissance survey recommendations (KHC 2011).

An intensive level survey of the four architectural resources recommended for further investigation as a result of the reconnaissance survey was conducted in August 2013. The resources consist of: two cemeteries (LR149 and LR150); a late-nineteenth century vernacular T-plan house (LR151); and an early-twentieth century vernacular central passage, double pile house (LR188) (Figure 4-3; Table 4-15).

Archival and historical research and detailed field survey were undertaken to evaluate the NRHP eligibility of each property. Based on the field and research data, the survey concluded that none of the resources are eligible because they do not meet the NRHP criteria for eligibility (Cardno 2014b). The KHC concurred that the resources are not eligible for the NRHP (KHC 2014) (Appendix A, Agency Coordination).



Table 4-15. Architectural Resources in the Payne Gap Site APE Evaluated for NRHP Eligibility Site

Number Property Name Year Built Description NRHP

Eligibility LR149 Laurel Fork Cemetery 1918–present Cemetery Not Eligible LR150 Wright Cemetery 1863–1961 Private, family cemetery Not Eligible LR151 Samuel J. Wright House Ca. 1885 Vernacular T-plan residence Not Eligible

LR188 Holbrook-Craft House Ca. 1903–1914 Vernacular central passage, double pile house Not Eligible


The cultural resources surveys for the proposed action did not identify any archaeological sites or architectural resources eligible for inclusion in the NRHP in the APE for the Payne Gap site. Therefore, Alternative 1 would have no effect on NRHP-listed or eligible cultural resources.


Under the No Action Alternative, the USP and FPC would not be constructed and the site would remain undeveloped and no potential impacts to cultural resources would occur.

Mitigation 4.9.4

Alternative 1 would have no impact to NRHP-listed or eligible cultural resources; therefore, no mitigation is required.



The Payne Gap site has two domestic single household wells located on the northern portion of the site. One well is at an elevation of 1,500 feet with water found at 60 feet below the surface. The second well is located at an elevation of 1,480 feet with water found at an elevation of 40 feet below the surface (KGS 2013). There are no groundwater wells on the Roxana site but there is a domestic single household well located north of the site at an elevation of 1,200 feet with a depth to water of 80 feet. Groundwater flow tends to follow the slope topography. Variations in groundwater conditions are expected based on location and elevation across the site, seasonal conditions, and weather patterns. Both sites are underlain by the Breathitt Group which is comprised of the Pikeville Formation and the Hyden Formation at both sites; however, only the Roxana site is also underlain by the Four Corners Formation. The Breathitt Group yields more than 500 gallons per day in more than three-quarters of the wells drilled in valley bottoms, more than 500 gallons per day in about three quarters of the wells on hillsides, and more than 100 gallons per day to nearly all wells on ridges within Letcher County (KGS 2013). There are no sole source aquifers underlying either site (USEPA 2013b).

The quality of the groundwater in Letcher County ranges from moderately hard in most of the county to moderately soft south of Pine Mountain. Naturally occurring contaminants present in the groundwater consist of sulfate, salt (sodium chloride), iron, and manganese (University of Kentucky 2013b).

According to the Kentucky Division of Water, Groundwater Branch, Letcher County has areas of moderate and high sensitivity to groundwater pollution. The hydrogeologic sensitivity reflects the ease and speed with which a contaminant can move into and within a groundwater system. The hydrogeologic sensitivity of Letcher County has been given a value of three out of five, with five being the most



susceptible to groundwater pollution and one being the least susceptible. The region is given a three due to subcutaneous drain and enlarged fractures influence groundwater recharge, fissure networks influence flow, and bidirectional dispersal patters influence overall dispersion (KDEP 1994).

4.10.1.1 Water Quality

Water Quality refers to the suitability of water for a particular use based on selected physical, chemical, and biological characteristics. Potential uses considered include potable water, irrigation, and water able to support life. For the purposes of this EIS, water quality is considered with the statutory requirements regarding water quality conditions.

Water Quality is regulated under the Federal Water Pollution Control Act, as amended by the CWA. The CWA prohibits spills, leaks, or other discharges of oil or hazardous substances into the waters of the U.S. in quantities that may be harmful. Direct discharges of effluents are regulated under the CWA through National Pollutant Discharge Elimination System permit program administered by the USEPA or under state National Pollutant Discharge Elimination System programs approved by the USEPA. The CWA also requires each state to establish water quality standards for its surface waters derived from the amount of pollutants that can be assimilated by a body of water without deterioration of a designated use. Waters not meeting the water quality standards may require the establishment of a TMDL for the waterbody. Impaired waters requiring a TMDL are called 303 (d) listed waters (KDEP 2013).

According to Environmental Protection Agency data none of the streams on either site have been assessed. Subsequently there are no identified impaired waters or TMDLs for either of the sites (USEPA 2013a). The closest assessed water body to the Payne Gap site is Fish Pond, located north of the site, on the opposite side of Kona Cut Road (U.S. Route 119). Fish Pond was determined to be good for secondary contact recreation water, warm water aquatic habitat, and cold water aquatic habitat. The closest assessed water body to the Roxana site is the North Fork of the Kentucky River, located north of the site on the opposite side of Route 588/ 160. The North Fork of the Kentucky River was assessed for primary contact recreation and was determined to be impaired as a result of elevated levels of fecal coliform. The elevated levels of fecal coliform were believed to be the result of point source discharges from sewage or packaging plants (USEPA 2013a).

4.10.1.2 Floodplains

EO 11988, Floodplain Management, sets forth the responsibilities of federal agencies for reducing the risk of flood loss or damage to personal property, minimizing the impacts of flood loss, and restoring the natural and beneficial functions of floodplains. This order was issued in furtherance of the National Flood Insurance Act of 1968 and the Flood Disaster Protection Act of 1973.

4.10.1.3 Wetlands and Waters of the U.S.

Wetland delineations were conducted in May 2011 and August 2014. Hydrology at the site has been highly disturbed as a result of historic mining activities. The delineation included the identification of wetlands and Waters of the U.S.

During delineations approximately 2.84 acres (1.15 hectares) of wetlands were identified within the proposed project area on the Payne Gap site. The majority of the wetlands are located immediately adjacent to an existing or historic road which has impacted water movement in the area. NWI does not depict any wetlands onsite, within or outside of the proposed project area. In addition, several



intermittent, perennial and ephemeral streams were delineated on site (TEC, Inc. 2011b, TEC, Inc. 2011c, and Cardno 2014c).

Hydrology supporting the wetlands is a result of both groundwater and surface water; runoff and direct precipitation. Dominant vegetation within the wetlands identified at the Payne Gap site consists of Eleocharis obtusa, Juncus effuses, Typha latifolia, and Carex lurida.

Figure 4-4 depicts the wetlands and streams delineated within the Payne Gap site and Table 4-16 lists the acreages of wetland by type.

Table 4-16. Wetland and Streams Delineated at Payne Gap Feature Type Payne Gap Site

Acres/Hectares Linear Feet Wetlands Palustrine Emergent 0.9/0.4 N/A Palustrine Scrub-Shrub 1.2/0.5 N/A Palustrine Forested 0.8/0.3 N/A Riverine Jurisdictional Stream N/A 13,317 Non-Jurisdictional Stream N/A -

Total 2.9/1.2 13,317 Note: N/A = Not Applicable.

Based on Federal Emergency Management Agency floodplain mapping, there are no 100-year floodplains at the Payne Gap site (Marshall Miller 2012a).


Implementation of the proposed action is not anticipated to affect groundwater, as excavation and construction activities are anticipated to occur at elevations well above the groundwater table.

It is not anticipated that water quality of nearby streams and wetlands would be adversely impacted by on site construction. BMPs would be implemented based on an approved erosion and sediment control plan that would minimize sediment and pollutants from the construction site being carried into nearby water courses.

Implementation of the proposed action at the Payne Gap site would result in approximately 10,512 linear feet of stream impacts, 0.43 acres (0.17 hectares) of impacts to palustrine emergent wetlands, 0.76 acres (0.31 hectares) of impact to palustrine forested wetlands, and 1.2 acres (0.48 hectares) of impacts to palustrine scrub-shrub wetlands. These impacts would be to the streams and wetlands delineated in 2011 and 2014 (refer to Table 4-16) and would result primarily from the excavation and grading activities that would be required to prepare the site for the development of the USP, FPC, ancillary buildings, and roads.

No floodplains are present on the Payne Gap site; therefore no impacts to floodplains would occur.


Under the No Action Alternative, the Payne Gap site would not be developed and no impacts to surface waters or wetlands would occur.

Mitigation 4.10.4

The Bureau met with the USACE on May 19, 2015 to discuss mitigation related to wetland and stream impacts. Since the Payne Gap site is not the preferred alternative no mitigation would be warranted for the site at this time.



Figure 4-4. Payne Gap Wetlands and Waters of the U.S.





Biological resources include living, native, or naturalized plant and animal species and the habitats where they occur. Habitat can be defined as the resources and conditions present in an area that supports the existence of a plant or animal (Hall et al. 1997). Although the existence and preservation of biological resources are intrinsically valuable, these resources also provide aesthetic, recreational, and socioeconomic values to society.

This analysis focuses on species and vegetation types that are important to the function of the ecosystem, of special societal importance, or are protected under Federal or state law or statute. For the purposes of this EIS, these resources are divided into three major categories: vegetation, wildlife, and special-status species.

Vegetation includes terrestrial plant communities and the analysis focuses on vegetation types that are important to the function of the ecosystem or are protected under Federal or State law.

Wildlife includes all common animal species, with the exception of those identified as special-status species (see below). The wildlife category includes invertebrates, fish, amphibians, reptiles, mammals, and birds, including native bird species protected under the MBTA.

Special-status species includes plant and animal species that are listed or proposed for listing by USFWS as threatened and endangered or are candidate species under the ESA. ESA candidate species are plant or animal species for which USFWS has sufficient information on file regarding biological vulnerability and threats to support a proposal that would list them as endangered or threatened under the ESA, based on the most recent candidate review. In addition, designated and proposed critical habitat for ESA-listed species are also included in this EIS, as appropriate. Critical habitat is a specific geographic area(s) that contains features essential for the conservation of a threatened or endangered species and that may require special management and protection. This section also addresses species that are listed by the State of Kentucky as threatened or endangered.

4.11.1.1 Vegetation

The Payne Gap site is primarily covered in mature hardwood forest with herbaceous and scrub shrub vegetation dominating areas previously disturbed by historic strip mining activities and along the shoulders of the site access roads. Site observations indicate upland vegetation on the Payne Gap site includes, American beech (Fagus grandifolia), tuliptree (Liriodendron tulipifera), northern red oak (Quercus rubra), sourwood (Oxydendrum arboreum), American elm (Ulmus americana), Allegheny blackberry (Rubus allegheniensis), autumn olive (Elaeagnus umbellata), white clover (Trifolium repens), sericea lespedeza (Lespedeza cuneata), multiflora rose (Rosa multiflora), Kentucky bluegrass (Poa pratensis), and summer grape (Vitis aestivalis). Wetland vegetation includes American sycamore (Platanus occidentalis), black willow (Salix nigra), green ash (Fraxinus pennsylvanica), jewelweed (Impatiens capensis), common rush (Juncus effusus), broadleaf cattail (Typha latifolia), fowl mannagrass (Glyceria striata), sallow sedge (Carex lurida), and woolgrass (Scirpus cyperinus).

4.11.1.2 Wildlife

Due to relative proximity wildlife on both sites are believed to be similar; however, during a site visit a herd of eastern elk (Cervus elaphus) was observed on the Payne Gap site. Species likely to be found on



both sites includes red-winged blackbirds (Agelaius phoeniceus), tufted titmouses (Baeolophus bicolor), red-tailed hawks (Buteo jamaicensis), coyotes (Canis latrans), Virginia opossums (Dipelphis virginiana), American black bears (Ursus americanus), eastern gray squirrels (Sciurus carolinensis), green frogs (Rana clamitans melanota), American toads (Bufo americanus), black rat snakes (Elaphe obsoleta obsolete), southern flying squirrels (Glaucomys volans), eastern spotted skunks (Spilogale putorius), copperheads (Agkistrodon contortrix), eastern hognose snakes (Heterodon platirhinos), fence lizards (Sceloporus undulates), ,wild turkeys (Meleagris gallopavo), and white tailed deer (Odocoileus virginianus) (Kentucky Department of Fish and Wildlife Resources 2013).

The MBTA is the primary legislation established to conserve migratory birds. The act prohibits taking, killing, or possessing migratory birds unless permitted by regulation.

4.11.1.3 Federally Threatened and Endangered and State Listed Special Status Species

Due to the number of state listed species listed by Kentucky as potentially occurring in Letcher County and subsequently on the two proposed sites the following section will focus on federal listed species. A full list of special status species and their status is included in Table 4-17.

Table 4-17. State and Federal Report of Endangered, Threatened, and Special Concern Plants, Animals, and Natural Communities of Letcher County, Kentucky

Scientific Name Common Name Status (State/Federal) Liverworts Plagiochila caduciloba Gorge Leafy Liverwort E/N Mosses Anomodon rugelii None T/N Brachythecium populeum Matted Feather Moss E/N Cirriphyllum piliferum None T/N Dicranodontium asperulum None E/N Entodon brevisetus None E/N Neckera pennata None T/N Oncophorus raui None E/N Polytrichum pallidisetum A Hair Cap Moss T/N Polytrichum strictum None E/N Sphagnum quinquefarium Five-ranked Bogmoss E/N Vascular Plants Adlumia fungosa Allegheny-vine H/N Angelica triquinata Filmy Angelica E/N Baptisia tinctoria Yellow Wild Indigo T/N Botrychium matricariifolium Matricary Grape-fern E/N Boykinia aconitifolia Brook Saxifrage E/N Carex aestivalis Summer Sedge E/N Carex appalachica Appalachian Sedge T/N Castanea pumila Allegheny Chinkapin T/N Circaea alpine Small Enchanter's Nightshade S/N Corydalis sempervirens Rock Harlequin S/N Cymophyllus fraserianus Fraser's Sedge E/N Cypripedium parviflorum Small Yellow Lady's-slipper T/N Eupatorium steelei Steele's Joe-pye-weed T/N Gentiana decora Showy Gentian S/N Hexastylis contracta Southern Heartleaf E/SOMC Houstonia serpyllifolia Michaux's Bluets E/N Hydrophyllum virginianum Eastern Waterleaf T/N




Scientific Name Common Name Status (State/Federal) Juglans cinerea White Walnut T/SOMC Leucothoe recurve Red-twig Doghobble E/N Lilium superbum Turk's Cap Lily T/N Listera smallii Kidney-leaf Twayblade T/N Monotropsis odorata Sweet Pinesap T/SOMC Oenothera oakesiana Evening Primrose H/N Oenothera perennis Small Sundrops E/N Orontium aquaticum Golden Club T/N Pogonia ophioglossoides Rose Pogonia E/N Prosartes maculate Nodding Mandarin S/N Sanguisorba Canadensis Canada Burnet E/N Saxifraga michauxii Michaux's Saxifrage T/N Saxifraga micranthidifolia Lettuce-leaf Saxifrage E/N Solidago curtisii Curtis' Goldenrod S/N Trillium undulatum Painted Trillium T/N Terrestrial Snails Glyphyalinia rhoadsi Sculpted Glyph T/N Neohelix dentifera Big-tooth Whitelip T/N Patera panselenus Virginia Bladetooth S/N Crustaceans Cambarus bunting Longclaw Crayfish S/N Cambarus parvoculus Mountain Midget Crayfish T/N Insects Amphiagrion saucium Eastern Red Damsel E/N Calephelis borealis Northern Metalmark T / T/N Erora laeta Early Hairstreak T/N Litobrancha recurvate A Burrowing Mayfly S/N Papaipema speciosissima Osmunda Borer Moth E/N Phyciodes batesii Tawny Crescent H/SOMC Stylurus notatus Elusive Clubtail E/SOMC Stylurus scudderi Zebra Clubtail E/N Fishes Chrosomus cumberlandensis Blackside Dace T/LT Etheostoma sagitta Cumberland Arrow Darter S/C Amphibians Cryptobranchus alleganiensis alleganiensis

Eastern Hellbender E/SOMC

Plethodon wehrlei Wehrle's Salamander E/N Breeding Birds Accipiter striatus Sharp-shinned Hawk S/N Corvus corax Common Raven T/N Pheucticus ludovicianus Rose-breasted Grosbeak S/N Tyto alba Barn Owl S/N Vermivora chrysoptera Golden-winged Warbler T/SOMC Mammals Clethrionomys gapperi maurus Kentucky Red-backed Vole S/SOMC Corynorhinus rafinesquii Rafinesque's Big-eared Bat S/SOMC Mustela nivalis Least Weasel S/N Myotis leibii Eastern Small-footed Myotis T/SOMC Myotis sodalist Indiana Bat E/LE




Scientific Name Common Name Status (State/Federal) Sorex cinereus Cinereus Shrew S/N Sorex dispar blitchi Long-tailed Shrew E/N Spilogale putorius Eastern Spotted Skunk S/N Ursus americanus American Black Bear S/N Communities Appalachian seep/bog Appalachian seep/bog T/N

Notes: N = None, E = Endangered, T = Threatened, S = Special Concern, SOMC = Species of Management Concern, H = Historic. Source: Kentucky State Nature Preserves Commission 2013.

The gray bat (Myotis grisescens) is federally listed as endangered and listed by Kentucky as threatened. The gray bat roosts in caves throughout the year although suitable caves are rare. For winter hibernacula the bats require vertical caves with domed halls. The winter caves must also have a temperature of between 6 and 11 degrees Celsius. Forested areas along the banks of streams and lakes provide important protection for adults and young. Summer caves are always within 1 km of a river or reservoir where the bats forage. Forests provide important feeding areas for young bats, which will not forage in areas where the forests have been cleared (Natureserve 2013a).

The Indiana bat (Myotis sodalis) is federally listed as endangered and is listed by Kentucky as endangered. The Indiana bat hibernates in caves; however, maternity sites are generally behind loose bark of dead or dying trees or in tree cavities. They forage in riparian areas, upland forests, ponds, and fields, but forested landscapes are the most important habitat. They typically hibernate in the coldest area of a cave to ensure a low enough metabolic rate in order to conserve fat reserves throughout the winter; however they will move away from areas that dip below freezing. Known roost tree species include elm, oak, beech, hickory, maple, ash, sassafras, birch, sycamore, locust, aspen, cottonwood, pine, and hemlock with a preference for trees with exfoliating bark (Natureserve 2013b).

According to the USFWS there is no federally designated Critical Habitat on either site (USFWS 2013).

Based on coordination with USFWS the Payne Gap site is considered to have the potential for Indiana bat as well as gray bat. A Phase I survey conducted in December 2014 confirmed the presence of both winter and summer habitat (Copperhead Environmental Consulting 2015). In addition, one mine opening contained a torpid Indiana bat at its entrance. USFWS concurred with the findings of the Phase I survey and indicated additional studies at the Payne Gap site would be required if this site were moved forward for development (Appendix A). The Bureau met with USFWS on May 20, 2015 to discuss additional studies and mitigation requirements (Appendix A).

In addition, the Kentucky arrow darter is known to exist in the upper Kentucky River basin. Habitat for the species consists of pools and transitional areas between riffles and pools in moderate to high gradient streams. The streams within the project area are primarily small channels that do not contain riffle and pool complexes (USFWS 2013).


4.11.2.1 Vegetation

Approximately 218 acres (88 hectares) of forested area would be impacted by the proposed action. These impacts would be the result of excavation and grading activities required to prepare the site for development.



4.11.2.2 Wildlife

Wildlife species found on the sites would likely be displaced during construction activities due to the loss of habitat and increases in noise. However, over 535 acres (217 hectares) of the site itself would remain undisturbed and continue to provide habitat, including breeding and foraging areas, for wildlife species found on-site. Additionally, the site is surrounded by similar habitat that could accommodate species that are displaced by construction activities. Based on the available habitat that will remain on site and habitat adjacent to the site (Jefferson National Forest), it is anticipated that these impacts would not adversely affect wildlife species that are currently present on-site.

Use of the non-lethal/lethal fence has the potential to result in adverse impacts to small animals and avian species, should they pass through the outer fences and into the area of the non-lethal/lethal fence.


Implementation of the proposed action at the Payne Gap site has the potential to impact Indiana bats, northern long-eared bats and gray bats. Approximately 218 acres (88 hectares) of summer roosting habitat would be impacted at the Payne Gap site. Additionally, based on the presence of mine openings and an Indiana bat, USFWS requested additional studies be conducted at the Payne Gap site to further assess impacts if the proposed action were to be implemented at the site. These studies would include conducting spring or fall portal surveys on all suitable mine openings that may be either directly or indirectly impacted by the proposed action. Based on the Phase I survey and coordination with USFWS there is the potential for significant impacts to both summer roosting habitat and winter hibernaculum. Indirect impacts may come from the noise from the proposed outdoor firing range. The range would be used approximately once a month for small arms training and maintenance.

It is not anticipated that the Kentucky arrow darter would be impacted by the project. The streams within the project site are small channels and do not contain riffle pool complexes. Additionally, conductivity measurements were taken within streams on the project site. Conductivity measurements ranged from 562 microseconds (µS) to 1,970 µS. Studies have demonstrated that Kentucky arrow darters are not likely to be present when conductivity levels exceed approximately 250 µS; therefore, no impacts to Kentucky arrow darter are anticipated (USFWS 2010).


Under the No Action Alternative, the Payne Gap site would not be developed and there would be no impacts to vegetation, wildlife, or threatened and endangered species.

Mitigation 4.11.4

Mitigation measures for construction impacts to vegetation and wildlife would be to minimize disturbance of existing vegetation to the greatest extent possible. An open area with a direct line of site is required for the areas surrounding the USP and FPC; however, upon completion of construction, disturbed areas would be re-vegetated to the maximum extent possible while maintaining the Bureau’s site requirements.

The Bureau met with USFWS on May 20, 2015 to discuss the Payne Gap site and potential additional studies and mitigation. If the site were to be developed additional studies of winter hibernaculum to further assess impacts and potential mitigation would be required. USFWS currently has a Conservation Memorandum of Agreement (CMOA) for impacts to summer habitat of 100 acres (40 hectares) or less. This site would not be covered under the CMOA; therefore, formal Section 7 consultation with USFWS



would be required for development of the Payne Gap site. Additional studies of summer and winter habitat and the preparation of a biological assessment also would be required. USFWS would then render a biological opinion on the findings of the biological assessment and determine if a take can be authorized. The biological assessment would be required to cover both summer roosting habitat and winter hibernaculum. Based on discussions with USFWS, since this is not the preferred alternative and development of this site is not anticipated, no additional studies or coordination are required at this time (Appendix A). Should this change in the future, the Bureau would be required to notify USFWS, conduct any required studies, and initiate formal Section 7 consultation, if necessary, prior to any development of the site.

The Bureau has conducted prior EAs regarding the installation of non-lethal/lethal fences for potential impacts, especially to avian and small mammal species. These prior assessments have found less than significant adverse impacts and less than significant impacts are anticipated with the non-lethal/lethal fence to be installed as part of this proposed action. However, following activation of the non-lethal/lethal fence, the Bureau would monitor the fence line to determine if wildlife, particularly avian species are being adversely effected. The Bureau would collect data regarding these occurrences including identification of species and photographs. The data collected would be used to document and analyze emerging trends. If adverse effects were identified through the analysis of data collected the Bureau would contact USFWS and appropriate state wildlife agencies to determine if changes to the operation of the fence are warranted.



4.12.1.1 Hazardous Materials

The proposed USP and FPC construction site is located in a relatively undeveloped area. No hazardous materials are known to be in storage or in use in this area. According the USEPA “Cleanups In My Community” mapping tool, there are no Brownfield, Superfund or Resource Conservation and Recovery Act (RCRA) Corrective Action sites in the vicinity of the proposed project area. No sites in the town of Payne Gap were listed in USEPA’s Toxic Substances Control Act (TSCA), Toxics Release Inventory (TRI), or RCRA databases. No hazardous materials or evidence of their presence (i.e., stressed vegetation, stained soils, drums) on the site were observed during site visits conducted by Cardno in 2011, 2013, and 2014.

4.12.1.2 Hazardous Wastes

The proposed USP and FPC construction site is located in a relatively undeveloped area. No hazardous wastes are known to be in storage or generated in this area. According the USEPA Cleanups In My Community mapping tool, there are no Brownfield, Superfund or RCRA Corrective Action sites in the vicinity of the proposed project area. No sites in the town of Payne Gap were listed in USEPAs TSCA, TRI or RCRA databases. No hazardous wastes or evidence of their presence (i.e., stressed vegetation, stained soils, drums, batteries) on the site and no evidence of acid mine drainage was observed during site visits conducted by Cardno in 2011, 2013, and 2014.

4.12.1.3 Radon

Radon is a naturally occurring, colorless, odorless, radioactive gas produced by the decay of uranium in rock and soil. Radon is a known carcinogen, responsible for increasing the risk of lung cancer when



inhaled. Electrically charged radon atoms can attach to indoor air dust particles. Subsequently these dust particles may be inhaled and adhere to the lining of the lungs. The deposited atoms decay by emitting radiation that has the potential to cause cellular damage. Typically outside air contains very low levels of radon (USEPA 2015c), but tends to accumulate in enclosed indoor spaces. When present, radon gas would typically concentrate in relatively airtight buildings with little outside air exchange. The USEPA classifies Letcher County as having a moderate potential for radon intrusion (Zone 2). Zone 2 counties have a predicted average indoor radon screening level between 2 and 4 pCi/L. The USEPA action level for radon is 4 pCi/L.


4.12.2.1 Hazardous Materials

Construction activities would require the use of hazardous materials. The majority of the hazardous materials expected to be used are common to construction and include diesel fuel, gasoline, and propane to fuel the construction equipment; hydraulic fluids, oils, and lubricants; and batteries. The transport and use of hazardous materials would have the potential to result in accidental spills that could adversely impact soil and groundwater on and adjacent to the construction site or along transportation routes. Hazardous materials associated with construction activities would be delivered and stored in a manner that would prevent these materials from leaking, spilling, and potentially polluting soils or groundwater, and in accordance with applicable federal, state, and local environmental and public and occupational health and safety regulations. With the implementation of appropriate handling and management procedures, hazardous materials used during construction would have no significant impacts to the environment.


Hazardous waste would be generated during construction activities and would include but not be limited to empty containers, spent solvents, waste oil, spill cleanup materials (if used), and lead-acid batteries from construction equipment. Construction contractors would be responsible for safely removing these construction-generated wastes from the construction site and for arranging for recycling or disposal in accordance with applicable regulations. The total monthly generation of hazardous waste during construction is anticipated to be less than 100 kilograms during a calendar month. The construction contractor would be responsible for determining their regulatory status regarding hazardous waste generation during construction, and obtaining and maintaining compliance in accordance with federal and state laws. Hazardous wastes associated with construction activities would be handled and stored in a manner that would minimize human exposure to these materials and prevent these materials from polluting soils or groundwater, and in accordance with applicable federal, state, and local environmental and human health and safety regulations. Adherence to these policies, procedures, and regulations would minimize the potential impacts from exposure and accidental releases during revetment construction. In the event of an accidental release, contaminated media would be treated on-site or would be promptly removed and disposed of in accordance with applicable federal and state regulations. With the implementation of appropriate handling and management procedures, hazardous wastes generated during construction would have no significant impacts to the environment.

Operation of the UPC and FPC would require the use of small amounts of hazardous materials such as petroleum, oils and lubricants for lawn maintenance equipment, pesticides and paints. These materials would be acquired as needed and large volumes would not be stored on site. Those volumes that are stored



on site would be stored, used and disposed in accordance with applicable regulations and would have no significant impacts on the environment.

Expended lead and brass from firing range operations would be recovered and recycled as part of general range maintenance activities and would have no significant impacts to the environment.

4.12.2.3 Radon

Structures intended for human occupancy may be equipped with radon detectors or may incorporate best management practices for radon control into their design to ensure there are no impacts from radon.


Under the No Action Alternative, the Payne Gap site would not be developed and there would be no impacts associated with hazardous materials and waste.

Mitigation 4.12.4

Alternative 1 would have no significant impacts to hazardous materials and wastes; therefore, no mitigation is required.

Although there are no federal regulations that mandate an acceptable level of radon exposure, the USEPA recommends the voluntary radon action level developed and issued by the American Society for Testing and Materials International (ASTMI), Standard Practice for Installing Radon Mitigation Systems in Existing Low-Rise Residential Buildings, ASTMI E-2121. Radon resistant construction techniques may be used to mitigate potential impacts from radon. In addition, periodic testing of the facility may be conducted to verify that no unacceptable radon gas buildup occurs. Installation of radon mitigation systems may also occur, as appropriate.


5.0 Alternative 2-Roxana 5-1 July 2015

5.0 ALTERNATIVE 2 – ROXANA



Land use associated with the proposed location of Alternative 2 consists primarily of forest, residential area, strip mines, oil and gas wells and a small model airplane airstrip. The area was previously deep mined; however mining activities no longer occur at the site. Land use surrounding the site is also primarily forested, with small single family residential homes in the area. There are also several state parks and nature preserves within the area. They include Bad Branch Falls State Nature Preserve, Kingdom Come State Park, and Pine Mountain Wildlife Management Area. There are no zoning ordinances or land use classifications identified for this area (DePriest 2013). Land use associated with the Roxana site is depicted in Figure 5-1.


Changes to land use would occur on the 800-acre (324-hectare) Roxana site. The site would be converted from an undeveloped open space containing a mix of grass and scrub-shrub vegetation to a government institution consisting of several facilities, parking lots, etc. Additionally, the model airplane strip would be removed. The oil and gas wells would require closure and these impacts are further discussed in Section 5.8, Infrastructure and Utilities.


The No Action Alternative would be the same as that described in Section 4.1.3.

Mitigation 5.1.4

Mitigation for Alternative 2 would be the same as that described for Alternative 1 in Section 4.1.4.

TOPOGRAPHY, GEOLOGY AND SOILS 5.2


The topography at the Roxana site has been significantly impacted by mountaintop removal coal mining. A plateau resulting from mining has replaced a mountain ridge in the central portion of the site. This change has not been accounted for on USGS topographic maps; however, the highest point and lowest points of the site remain unchanged. The highest elevation is located in the south eastern portion of the site at an elevation of approximately 1,850 feet AMSL. The lowest elevation on site is approximately 1,035 feet AMSL, located in the north western portion of the site adjacent to the North Fork of the Kentucky River.

The Roxana site underlain by the Breathitt Group which is comprised of the Pikeville Formation and the Hyden Formation; however, the Roxana site is also underlain by the Four Corners Formation. The geology underlying the Roxana site is primarily the Hyden Formation (KGS 2013).


5-2 5.0 Alternative 2-Roxana July 2015

Figure 5-1. Roxana Land Use



The three most common soils on the Roxana site are the Cloverlick-Kimper-Highsplint complex, (30 to 65 percent slopes), the Kaymine, Fairpoint and Fiveblock soils map unit (2 to 70 percent slopes), and the Shelocta-Highsplint (30 to 65 percent slopes). To a lesser degree the following soils underlie the site; Allegheny Loam (2 to 25 percent slopes), Dekalb-Gilpin-Rayne complex (25 to 65 percent slopes), Fiveblock and Kaymine soils (0 to 30 percent slopes), Gilpin-Shelocta complex (12 to 25 percent), Grigsby sandy loam (occasionally flooded), Grigsby-Urban land complex (0 to 6 percent slopes), Urban land-Udorthents complex (0 to 15 percent slopes), and Urban land-Udorthents-Grigsby complex (0 to 6 percent slopes) (NRCS 2013).

The Roxana site contains a small area of soils designated as farmland of statewide importance (NRCS 2013). The soil is Allegheny Loam and is located in the floodplain of the North Fork of the Kentucky River in the northernmost portion of the site. None of the soils associated with the Roxana site are listed as hydric by NRCS.


Development of the site would require significant excavation and fill activities to create a level pad for construction of the facilities or to build a road. A 2:1 fill slope and a 1:1 cut slope were used in the estimate adjacent to the pads and roads to transition to the original topography at the Roxanna site. More detail on the earthwork calculations can be found in Appendix B. As described in Section 2.5, Alternative 2 – Roxana, and Table 2-2 , Estimated Site Preparation Quantities for Alternative 2 – Roxana, of this document, excavation activities (cut) would include 2,928,992 cubic yards (2,239,375 cubic meters) of spoil material and 902,757 cubic yards (690,207 cubic meters) of rock. The excavated soil and rock would be compacted to create a structural fill in the building pads and the valleys. The amount of structural fill was estimated to be 2,087,607 cubic yards (1,596,090 cubic meters) and the spoil fill was estimated to be 2,205,394 cubic yards (1,686,115 cubic meters). All excavated materials would be used on-site for structural fill. The maximum cut (excavation) at Roxanna would be approximately 20 meters and the maximum fill would be approximately 65 meters. Removal of bedrock would require blasting activities. Impacts resulting from these activities would include loss of productive soil, erosion, and destabilization of slopes (as a result of cuts and fills). As a result of the excavation and fill activities, the topography of the site would change at the maximum cut from 465 meters to 445 meters MSL in the main building area and a maximum fill from 380 meters to 445 meters MSL in the main building area.



Mitigation 5.2.4

Mitigation for Alternative 2 would be the same as the mitigation and BMPs described for Alternative 1 in Section 4.2.4.



Under Alternative 2, the Bureau would acquire approximately 700 acres (283 hectares) of land known as the Roxana site. The site is located 7.5 miles west of Whitesburg in Letcher County, Kentucky (Figure 2-4). The affected environment of the socioeconomics and environmental justice study area for Alternative 2 would be the same as described for Alternative 1.




The socioeconomic and environmental justice impacts of Alternative 2 would be the same as described for Alternative 1 because construction costs and operation expenditures of the proposed USP and FPC would be essentially the same. Therefore, implementation of Alternative 2 would have beneficial impacts to socioeconomics and no impacts to environmental justice populations or to children.



Mitigation 5.3.4




Community facilities and services are similar for the Roxana site are similar to those described for the Payne Gap site in Section 4.4, with the exception of the local police and fire departments, as described below.

5.4.1.1 Police

The Whitesburg Police Department is comprised of six police officers, one chief of police, one second in command, and one secretary. They are currently short staffed one police officer. The department has eight squad cars and provides 24-hour coverage (Whitesburg Police Department 2013).

5.4.1.2 Fire

The Letcher County Fire and Rescue provide fire response to the area of the Roxana site. Letcher County Fire and Rescue is comprised of 32 firefighters (20 paid and 12 volunteer). Fifteen of the personnel are EMTs. Letcher County Fire and Rescue has three stations: Jeremiah, Blackey, and Hallie and services the southern portion of Letcher County. Fire rescue equipment includes five ambulances, two tanker trucks and three engines (Letcher County Fire and Rescue 2013).

Whitesburg Fire and Rescue consists of 30 firefighters (25 volunteer and 5 paid). Five of the firefighters are EMTs. The station has five engines and a boom truck with a snorkel. Whitesburg Fire and Rescue has mutual aid agreements with the rest of Letcher County and are able to assist with emergencies throughout the county if dispatched (Whitesburg Fire and Rescue 2013).

The Kings Creek Volunteer Fire Department is located on KY 60 approximately 1.5 miles from the Roxana site. The fire department has 23 volunteers, 1 pumper truck, and 2 large tanker trucks. The Kings Creek Volunteer Fire Department has relationships with other local volunteer fire departments and through a local paging system, can request assistance from these departments (Meade 2015).

5.4.1.3 Healthcare

Existing healthcare services are the same as those described for the Payne Gap site in Section 4.4.

5.4.1.4 Schools

Existing school conditions are the same as those described for the Payne Gap site in Section 4.4.




5.4.2.1 Police

The law enforcement groups that have jurisdiction over the area where the Roxana site is located would be able to provide assistance in the event of an emergency situation at the USP that required assistance beyond the capabilities of the USP. The individual law enforcement agencies have stated they would be willing to discuss the development of a MOU with the Bureau to provide these services. With the exception of the Whitesburg Police Department, law enforcement indicated this would not result in impacts to their services or require the hiring of additional staff; therefore, the proposed action would have no impact to law enforcement. The Whitesburg Police Department may be impacted due to the need for an additional officer and the potential need for additional equipment.

5.4.2.2 Fire

Fire departments that would provide emergency services for the area where the Roxana site is located would be able to provide assistance to the USP and FPC in the event there was an incident that was beyond the capabilities of the USP and FPC. The individual fire departments have indicated they would be willing to discuss the development of a MOU with the Bureau to provide these services. The fire departments indicated that this would not result in impacts to their services or require the hiring of additional staff; therefore, the proposed action would have no impact to emergency services.

5.4.2.3 Healthcare

Impacts to healthcare would be the same as those described for Payne Gap in Section 4.4.

5.4.2.4 Schools

Impacts to schools would be the same as those described for Payne Gap in Section 4.4.



Mitigation 5.4.4

With the exception of the potential for an adverse impact to the Whitesburg Police Department, no impacts to community facilities and services would occur; therefore, no mitigation would be warranted. With respect to the Whitesburg Police Department, the Bureau would discuss the development of a MOU with the chief of police and the Mayor of Whitesburg and determine the department’s status and what steps may be taken to off-set those impacts.



The Roxana site is located approximately 6.1 miles to the west of Whitesburg, Kentucky, and would be constructed to the south of KY 588 and to the west of KY 160. Proximate to the proposed facility, KY 588 is a two-lane roadway designated as a Class II highway. Class II highways have lower speed collector roads and are primarily designed to provide access, while KY 160 is classified as a rural major collector3 (KYTC 2014a). In terms truck weight, both KY 588 and KY 160 are Class “A” roadways that can accommodate trucks having a gross vehicle weight of up to 44,000 pounds (KYTC 2014c). Potential access points include a connection to the north to KY 588, a connection to the east to KY 160, and/or a



connection to the west to an existing roadway that is traverses north/south between KY 588 and Lilly Cornett Branch Road.

A traffic impact study was conducted for the proposed action in April 2015. Based on the analysis in the traffic impact study, current Annual Average Daily Traffic associated with KY 160 are 550 per day and 330 per day associated with KY 588 (Parsons 2015). KY 588 a.m. and p.m. peak periods both function at an LOS A.


The transportation network associated with the Roxana site is primarily two-lane unstriped rural roadways. The infrastructure would not be able to support construction equipment and vehicles traveling to the site.

As defined by KYTC, rural minor collectors “provide service to…smaller communities, link locally important traffic generators to larger towns, and collect traffic from local roads. They should be spaced at intervals consistent with population density to bring all developed areas within a reasonable distance of a collector road” (KYTC 2014a).

Per KYTC, rural major collectors “Provide service to county seats, larger towns, and other traffic generators of intracounty importance, which are not directly served by a higher system and link them to larger towns or routes with higher classifications. Examples of traffic generators for this classification include schools, shipping points, county parks, and important mining and agricultural areas” (KYTC 2014a).

For the purposes of this analysis it was assumed the most likely access to the site would be from KY 588.


This alternative would involve the same types of construction activity as Alternative 1, and would temporarily increase traffic volumes during the construction period. As discussed above in Section 4.5, trucks would be used to deliver/remove construction materials and equipment, and to haul excess fill material and/or construction debris. Because traffic volumes are relatively low on roadways that provide access to the site, the temporary increase in truck traffic is not expected to have a significant effect on street capacity. However, particularly heavy trucks could exceed the maximum weight limit of certain bridges located near the proposed action. This potential impact would be avoided or reduced to a less than significant level with the implementation of mitigation described below in Section 5.5.4, Mitigation. With the implementation of this measure, the addition of construction related trips is not expected to result in a significant traffic-related impact. Additionally, impacts to area KY 588 are anticipated due truck traffic transporting construction equipment and materials to the proposed site. KY 588 has narrow lane widths and pavement design that is not at a level for a national or state truck route (Parsons 2015).

5.5.2.2 Operation

The Roxana Alternative would involve the same types of activities and the same number of employees as the Payne Gap Alternative. Therefore, the traffic generation previously presented in Table 4-10 would also apply to this action alternative. Accordingly, Alternative 2’s operations traffic has the potential to incrementally increase congestion on the surrounding roadway network. Potential effects include increased delay at intersections and/or reduced travel speed on roadway segments. These potential



impacts would be avoided or reduced to a less than significant level with the implementation of mitigation described below in Section 5.5.4, Mitigation.

Table 5-1 depicts estimated trips in and out of the facility during a.m. and p.m. peak periods. Due to the same number of staff, these numbers are the same as those used for the Payne Gap alternative.

Table 5-1. Estimated Peak Hour Trip Generation AM Peak Hour Trips PM Peak Hour Trips

In Out Total In Out Total 97 59 156 55 149 204

Note::(a) Land use and trip rates from ITE Trip Generation Manual, 9th Edition (ITE 2012) for Land Use 571 (Prison). Source: Parsons 2015.

Based on the trip generation and existing conditions, the traffic impact analysis determined that KY 588 in the vicinity of the Roxana site would function at LOS B. Additionally, the traffic impact analysis determined that the intersection of KY 588 and the proposed access to the Roxana site would function at LOS A during a.m. and p.m. peak periods for both northbound and westbound traffic.

Based on the traffic impact analysis, there would be no significant impact to traffic.



Mitigation 5.5.4

Mitigation measures should include a requirement that the selected construction contractor perform an assessment of the routing of construction traffic to the site. The contractor would also be required to:

• Route construction vehicles so that gross vehicle weight does not exceed the maximum weight limitations established by the KYTC.

• Construction contractor would bond the roads where limitations may be exceeded and repair the roads upon completion of construction.

• Develop and implement a maintenance of traffic plan to maintain traffic flow when construction equipment is being transported to the site.

AIR QUALITY 5.6


The affected environment for Alternative 2 would be the same as the affected environment described for Alternative 1 as the sites are both in the Appalachian Intrastate Air Quality Control Region.


The results of the air emissions analysis show that construction and operational emissions would remain well below the significance thresholds and would not have a significant impact on the local or regional air quality. A summary of the analysis is presented below and the complete analysis is provided in Appendix C, Air Emission Calculations.


Direct impacts from emissions from construction would include combustion emissions from fossil fuel-powered equipment and fugitive dust emissions (PM10 and PM2.5) during clearing, demolition activities,



earth moving activities, and operation of equipment on bare soil. Table 5-2 presents estimates for the primary construction activities that would utilize heavy duty diesel equipment for the Roxana site.

Table 5-2. Construction Emission Estimates for Roxana Site

Site Year VOC Tons

CO Tons

NOx Tons

SO2 Tons

PM10 Tons

PM2.5 Tons

Roxana 1 3.27 13.87 42.32 0.83 158.71 18.05 Roxana 2 3.27 13.87 42.32 0.83 106.64 12.85

Fugitive dust from land disturbance activities would be the primary source of emissions during construction, with most of the emissions occurring during Year 1. PM10 emissions are estimated using wetting and other typical reduction practices to reduce dust release by 50 percent. PM10 emissions are predicted to be greatest in Year 1 at the Roxana site, at 158 TPY. These emissions, however, would remain well below the significance threshold of 250 TPY. Construction emissions would not have direct or indirect significant impacts on the region’s air quality.

Direct impacts to air quality may also include emissions from the burning of construction debris, if such an activity were undertaken during construction. Vegetative debris and/or demolition and construction materials would be disposed in accordance with all laws and regulations. Should open burning be necessary, it would be conducted in accordance with Title 401 of the Kentucky Administrative Regulations, Section 63 (401 KAR 63:005) Open Burning.

5.6.2.2 Operations

Impacts associated with Alternative 2 would be similar to those described for Alternative 1.


Under the No Action Alternative, construction of the USP and FPC would not occur. The No Action Alternative would not result in emissions of any air pollutants. Therefore, there would be no impact to regional air quality

Mitigation 5.6.4


NOISE 5.7


The affected noise environment at the Roxana site would be the same as those conditions described for the Payne Gap site in Section 4.7.1.


The environmental consequences associated with the Roxanna site would be the same as those described for the Payne Gap site in Section 4.7.2. The residences adjacent to the Roxana site are well over 200 feet from the majority of construction areas. Increases in noise would be short-term and only occur during daytime hours.





Mitigation 5.7.4

Mitigation and minimization measures would be the same as those described Alternative 1 in Section 4.7.3.




LWSD would provide service to the Roxana site. LWSD is currently in the process of extending their water system to the eastern property boundary of the proposed Roxana site. The water main at this location is 8 inches in diameter and has water pressure near the connection point of approximately 110 psi. Potable water would be provided by LWSD via this connection at the eastern property boundary (Cardno 2014a). LWSD is capable of providing 4 million gallons per day to the region.

5.8.1.2 Wastewater

LWSD would provide sanitary sewer service to the proposed Roxana site. As with the water service, LWSD is currently extending their wastewater collection service in the area of the Roxana site. The closest existing connection is approximately 2.75 miles from the Roxana site (Figure 5-2). LWSD does not currently have plans to extend the sanitary sewer service to the property boundary of the Roxana site (Cardno 2014a). LWSD has a permitted capacity of 600,000 gallons per day and currently treats approximately 300,000 gallons per day.

5.8.1.3 Natural Gas

The Roxana site contains multiple gas wells and gas transmission lines. There are fourteen Hayden Harper gas wells and one EQT gas well within the Roxana site (Cardno 2014a). Gas transmission lines are also adjacent to the Roxana site.

5.8.1.4 Electricity

The affected environment for Alternative 2 is the same as that as described for Alternative 1.


Birch Communications provides telecommunications services to the area where the Roxana site is located (Cardno 2014a). Birch Communications has the capacity to provide telecommunications service to the Roxana site.



Figure 5-2. Roxana Existing Utilities



5.8.1.6 Solid Waste

Solid waste for Alternative 2 is the same as that described for Alternative 1.

Environmental Consequence 5.8.2


Impacts to potable water associated with Alternative 2 would be the same as those described for Alternative 1.

5.8.2.2 Wastewater

Implementation of the proposed action under Alternative 2 would result in an increase of approximately 224,000 gallons per day. This would increase wastewater treatment at LWSD to 524,000 gallons per day, which would not result in LWSD exceeding their permitted capacity of 600,000 gallons per day; therefore, no adverse impacts to wastewater would occur.

5.8.2.3 Natural Gas

Implementation of the proposed action under Alternative 2 would require the closure of fifteen gas wells that are located within the site the Bureau would acquire for development of the proposed USP and FPC. It would take approximately six months to close these wells. Closure of the fifteen gas wells would result in significant impacts to Hayden Harper and EQT, the owners of the gas wells. The Bureau would be able to connect to the natural gas distribution system located adjacent to the Roxana property for the cost of the meter and tap. Costs for the meter and tap are estimated to be $110,000. There is sufficient natural gas available and use of natural gas at the USP and FPC would not impact natural gas availability

5.8.2.4 Electricity

Alternative 2 impacts would be the same as those described for Alternative 1.


Implementation of the proposed action under Alternative 2 would not result in impacts to the available capacity of Birch Communications; however, in order to provide the service a new remote terminal would need to be constructed, as well as the installation of approximately 4 miles of fiber optic cables and 0.5 miles of copper cable. Construction of the terminal and cables would be the responsibility of the Bureau (Cardno 2014a). Costs to complete construction and install the cables would be approximately $190,000.

5.8.2.6 Solid Waste

Impacts to solid waste under Alternative 2 would be the same as those described for Alternative 1.



Mitigation 5.8.4

Impacts to the gas wells associated with the Roxana site would require the Bureau to pay the owners of the wells (Hayden Harper and EQT) for the costs associated with closure and abandonment of the wells. The anticipated cost ranges between $300,000 to $1,000,000 per well based on the remaining production of each well. The anticipated cost to close all 15 wells is $12.75 million. No other mitigation would be required.




An APE was defined to take into consideration both potential direct and indirect effects to cultural resources from implementation of the proposed action. The APE for Alternative 2 includes the 700-acre (283-hectare) Roxana site and adjacent areas to the north (Figure 5-3). The APE extends beyond the north boundary of the Roxana site because of the potential for visual effects to any historic properties that may be present within the viewshed of the proposed federal correctional facility’s one- to four-story buildings. Effects to archaeological resources, however, would be limited to the 300-acre (121-hectare) area within the APE where construction (direct ground disturbance) would occur.


5.9.1.1 Archaeological Resources

Mapping, aerial photos, and a pedestrian reconnaissance in August 2011 and August 2014 indicated that the Roxana Farm Site had been completely disturbed by former surface mining activities. Photo-documentation was conducted at the site; however, no subsurface testing was completed. In addition, background research indicated that no previously identified archaeological sites were present at the proposed Roxana Farm Site. No archaeological resources eligible for listing on the NRHP are present and no further work was recommended at the Roxana site as a result of the 2011 and 2014 archaeological surveys. Concurrence was received from the SHPO on January 24, 2012 and on December 22, 2014 (Appendix A, Agency Coordination).

5.9.1.2 Traditional Cultural Properties

Under Section 106 of the NHPA, a federal agency is required to give consideration to issues of traditional religious or cultural areas concerning Native American groups. No TCPs have been identified within the project APE.

5.9.1.3 Architectural Resources

The 2011 reconnaissance survey of the Roxana site APE identified two architectural resources for further investigation; the other architectural resources in the APE were not recommended for further work because they were not associated with significant historical or architectural contexts of Letcher County and/or were in poor condition (TEC, Inc. 2011a). An intensive-level survey of two mid-twentieth century square-plan pyramidal houses (LR152 and LR153) was conducted in 2013 to determine the NRHP eligibility of the properties (Table 5-3, Figure 5-3). One of the houses (LR153) also included several domestic and agricultural outbuildings. Both properties were recommended not eligible for listing in the NRHP because they do not meet the NRHP criteria for eligibility (Cardno 2014b). The KHC concurred that both properties are not eligible (KHC 2014) (Appendix A, Agency Coordination).

Table 5-3. Architectural Resources in the Roxana Site APE Evaluated for NRHP Eligibility Site

Number Property Name Year Built Description

NRHP Eligibility

LR152 Pearl Whitaker House Ca. 1940 Square-plan pyramidal house Not Eligible LR153 George Whitaker House 1940 Square-plan pyramidal house and nine outbuildings Not Eligible



Figure 5-3. Roxana Architectural Resources




The cultural resources surveys for the proposed action did not identify any archaeological sites or architectural resources eligible for inclusion in the NRHP in the APE for the Roxana site. Therefore, Alternative 2 would have no effect on NRHP-listed or eligible cultural resources.



Mitigation 5.9.4

Alternative 2 would have no impact to NRHP-listed or eligible cultural resources; therefore, no mitigation is required.



The affected environment for the Roxana site is similar to that described in Section 4.10.1 for Payne Gap with respect to ground water, water quality, and floodplains.

The Roxana site is situated on top of a plateau which is the result of mining of a portion of the mountain. As a result of the mining onsite the hydrology of the site has been greatly disturbed. There are several ephemeral, intermittent, and perennial unnamed, small streams identified and mapped within proposed project area. Additionally, an open water wetland (pond) comprising approximately 0.41 acres (0.17 hectares) is located along the eastern boundary, north of Rise Branch.

Site specific wetland data was collected through onsite field work, aerial photographs, topographic maps, National Wetland Inventory wetland maps, and Natural Resources Conservation Service soil surveys. Based on these resources wetlands are present on the sites.

Wetlands associated with the Roxana receive their hydrology from surface runoff from the surrounding lands, groundwater and direct precipitation. Dominant vegetation within the wetland identified on site is typified by Typha latifolia, Salix nigra, Lindera benzoin, Microstegium vimineum, Osmunda cinnamomea, and Scirpus cyperinus.

Table 5-4 summarizes the wetland types and acreages, as well as streams and linear feet, identified within the Roxana site. Figure 5-4 depicts wetlands and streams delineated within the Roxana site.

Table 5-4. Wetland and Streams Delineated at Roxana

Feature Type Roxana Site

Acres/Hectares Linear Feet Wetlands Palustrine Emergent 0.8/0.3 N/A Palustrine Scrub-Shrub 1.4/0.6 N/A Palustrine Forested 0.7/0.3 N/A Palustrine Upland Island 0.2/0.1 N/A Riverine Jurisdictional Stream - 8,383 Non-Jurisdictional Stream - 182

Total 3.1/1.3 8,565 Notes: N/A = Not Applicable.


5.0 Additional Required Considerations 5-15 July 2015

Figure 5-4. Roxana Wetlands and Waters of the U.S.




Implementation of the proposed action at the Roxana Site would result in permanent impacts to approximately 4,117 linear feet of stream, 0.37 acres (0.15 hectares) of forested wetlands, 0.7 acres (0.28 hectares) of emergent wetlands, and 1.38 acres (0.56 hectares) of scrub-shrub wetlands due to site excavation and development. These impacts would be to the streams and wetlands delineated in 2011 and 2014 (Table 5-4) and would result primarily from the excavation and grading activities that would be required to prepare the site for the development of the USP, FPC, ancillary buildings, and roads.



Mitigation 5.10.4

The Bureau met with the USACE on May 19, 2015 to discuss mitigation for the Roxana site. Wetland mitigation would be paid into an in-lieu fee fund. Wetland impact mitigation is calculated by adding total acreage of wetlands to be impacted and multiplying by 2. Wetland impacts on the Roxana site total 2.43 acres X 2 = 4.86 AMUs (Adjusted Mitigation Units)to be purchased. To determine the cost associated with wetland mitigation, the Bureau would contact the Kentucky Department of Fish and Wildlife Resources to determine the cost of AMUs at the time of purchase. The last recent quote was $43,000 per AMU, which would equate to $208,980 for wetland impact mitigation at the Roxana Site. These rates may increase depending on when the Section 404 permit is acquired. Stream mitigation would be based on Ecological Integrity Units (EIU). The EIU is calculated based on the stream rating (assessed using the USEPA’s Rapid Bioassessment Protocol Sheets). To account for cumulative and temporary impacts the EIU is multiplied by 1.2 (20 percent cumulative and temporary impacts); the result is a total of 1,414 EIUs. The current In Lieu Fee Credits are $755 per credit (EIU). Therefore the total for stream mitigation would be $1,067,570 at current 2015 rates. When construction funding becomes available the Section 404 permit would be applied for and mitigation costs would be updated according to the current mitigation rates and permit requirements. Mitigation In Lieu Fees for stream and wetland mitigation combined, using 2015 In Lieu Fee rates would total $1,276,550.



5.11.1.1 Vegetation

A large portion of the Roxana site has been disturbed by historic mining activities which created a relatively level area on the mountaintop. A site visit indicated a level portion of the site is farmed and portions not under agriculture are routinely bushhogged or are dominated by scrub shrub vegetation (e.g., autumn olive, multiflora rose, etc.). The mountain slopes are primarily forested with the exception of slopes created by fill from mining which are dominated by invasive species such as autumn olive and paradise tree (Ailanthus altissima). Upland vegetation includes northern red oak, eastern red cedar (Juniperus virginiana), sericea lespedeza, paradise tree, Allegheny blackberry, Virginia pine (Pinus virgininana), bluestem broomsedge (Andropogon virginicus), tuliptree, American beech, Virginia creeper (Parthenocissus quinquefolia), Ohio buckeye (Aesculus glabra), red maple (Acer rubrum), stinging nettle (Urtica dioica), and Christmas fern (Polystichum acrostichoides). Wetland vegetation at the Roxana site includes American sycamore, woolgrass, black willow, spicebush (Lindera benzoin), Nepalese browntop



(Microstegium vimineum), small spike falsenettle (Boehemeria cylindrica), and cinnamon fern (Osmunda cinnamomea).

5.11.1.2 Wildlife

Wildlife associated with the Roxana site is the same as described for Alternative 1-Payne Gap wildlife in Chapter 3.11.1.

5.11.1.3 Federal Listed Threatened and Endangered Species and State Listed Threatened and Endangered Species

Federal and State listed threatened and endangered species is the same as described for Alternative 1-Payne Gap in Chapter 3.11.1. Coordination with USFWS indicates the Roxana site is in known P1/P2 swarming habitat for the Indiana bat.


5.11.2.1 Vegetation

Approximately 118 acres (48 hectares) of forested area would be impacted by the proposed action. These impacts would be the result of excavation and grading activities required to prepare the site for development.

5.11.2.2 Wildlife

Wildlife species found on the sites would likely be displaced during construction activities due to the loss of habitat and increases in noise. However, over 582 acres (236 hectares) of the site itself would remain undisturbed and continue to provide habitat, including breeding and foraging areas, for wildlife species found on-site. Additionally, the site is surrounded by similar habitat that could accommodate species that are displaced by construction activities. Based on the available habitat that will remain on site and habitat adjacent to the site (Jefferson National Forest), it is anticipated that these impacts would not adversely affect wildlife species that are currently present on-site.


Implementation of the proposed action at the Roxana site has the potential to impact Indiana bats and northern long-eared bats. Phase I bat habitat surveys were conducted for Indiana and northern long-eared bats. Based on the conceptual design, the proposed action would impact approximately 93 acres (38 hectares) of summer roosting habitat. The Bureau met with USFWS on May 20, 2015 to discuss additional studies and mitigation (Appendix A).

Impact assessment would include the potential noise from the proposed outdoor firing range. The range would be used approximately once a month for small arms training and maintenance.

It is not anticipated that the Kentucky arrow darter would be impacted by the project. The streams within the project site are small channels and do not contain riffle pool complexes. Additionally conductivity measurements were taken within streams on the project site. Conductivity measurements were taken within one stream that contained flow and the result was a conductivity of 332 µS. Studies have demonstrated that Kentucky arrow darters are not likely to be present when conductivity levels exceed approximately 250 µS; therefore no impacts to the Kentucky arrow darter are anticipated (USFWS 2010).





Mitigation 5.11.4

Mitigation measures for vegetation and wildlife would be the same as those described for Alternative 1 in Section 4.11.4.

BOP will mitigate for take of Indiana bats and northern long-eared bats through a Conservation Memorandum of Agreement (CMOA) following the guidance provided in the USFWS's April 2015 Conservation Strategy for Forest Dwelling Bats in the Commonwealth of Kentucky (Conservation Strategy). The Biological Opinion that supports the Conservation Strategy concludes with a “non-jeopardy” determination for adverse effects to the Indiana bat and the northern long-eared bat and exempts the take resulting from the habitat removal specified in the CMOA (the CMOA does not cover tree removal in June and July). Once the CMOA has been completed, BOP will be in compliance for these species for this project.

Under the CMOA, BOP would pay into the Imperiled Bat Conservation Fund for summer roosting habitat impacted by the proposed action. Payment into the fund would be based on the time of year habitat is removed. Based on 2015 mitigation rates, mitigation costs would range from $732,375 to $1,024,325. The Imperiled Bat Conservation Fund would then provide the mitigation fees to the Kentucky Natural Lands Trust to purchase and protect important bat habitat.



The proposed USP and FPC construction site is located in a relatively undeveloped area. No hazardous materials are known to be in storage or in use in this area. According the USEPA “Cleanups In My Community” mapping tool, there are no Brownfield, Superfund or RCRA Corrective Action sites in the vicinity of the proposed project area. No sites in the town of Roxana were listed in the USEPA’s TSCA or TRI databases. Three sites were listed in the USEPA RCRA database, Coastal Coal Company LLC, Enterprise Mining Company LLC and Roxana BP. All three sites are located to the east of the proposed project site and are unlikely to impact site conditions based on the topography and inferred hydrology of the area. Site visits conducted in 2011, 2013, and 2014 did not observe any hazardous materials or evidence of their presence (i.e., stressed vegetation, stained soils, drums) on the site.


The proposed USP and FPC construction site is located in a relatively undeveloped area. No hazardous wastes are known to be in storage or generated in this area. According the USEPA Cleanups In My Community mapping tool, there are no Brownfield, Superfund or RCRA Corrective Action sites in the vicinity of the proposed project area. No sites in the town of Roxana were listed in USEPAs TSCA, TRI or RCRA databases. Site visits conducted in 2011, 2013, and 2014 did not observe any hazardous wastes or evidence of their presence (i.e., stressed vegetation, stained soils, drums, batteries) on the site and no evidence of acid mine drainage was observed.



5.12.1.2 Radon

The USEPA classifies Letcher County as having a moderate potential for radon intrusion (Zone 2). Zone 2 counties have a predicted average indoor radon screening level between 2 and 4 pCi/L. The USEPA action level for radon is 4 pCi/L.


Environmental consequences identified for Alternative 2 would be the same as those described for Alternative 1.



Mitigation 5.12.4

Mitigation identified for Alternative 2 would be the same as that described for Alternative 1 in Section 4.12.4.


6.0 Relationship Between Short-Term Use and Long-Term Productivity 6-1 July 2015

6.0 RELATIONSHIP BETWEEN SHORT-TERM USE OF THE ENVIRONMENT AND THE MAINTENANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY

Regulations for the preparation of Environmental Impact Statements require they address the relationship between short-term use of the environment and the maintenance of long-term productivity.

Construction of proposed facilities on the site would last an estimated 30 months following ground-breaking. Construction would involve clearing and grubbing, excavating and filling, paving, erecting structures, installation of lighting and signage, and landscaping. There would also be temporary disruptions to traffic associated with construction vehicles and equipment utilizing area roadways. It is anticipated that disruptions would be temporary and that construction and operation of the proposed USP and FPC would generate economic productivity in terms of new construction jobs, new payrolls, induced personal income, purchasing of materials, supplies, and services, and potential purchasing of new homes by Bureau staff once the facility opens.

The economic viability of the Letcher County, Kentucky region would experience long-term benefits by virtue of the approximately 300 new permanent jobs that would need to be filled at the USP and FPC.


6-2 6.0 Relationship Between Short-Term Use and Long-Term Productivity July 2015



7.0 Irreversible and Irretrievable Commitments of Resources 7-1 July 2015

7.0 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES

Regulations for the preparation of EISs also require they address irreversible and irretrievable commitments of resources associated with the proposed action. Construction and operation of the proposed USP and FPC would result in both direct and indirect commitments of resources. In some cases, resources committed would be recovered in a relatively short period of time. In other cases resources would be irreversibly or irretrievably committed by virtue of being consumed or by the apparent limitlessness of the period of their commitment to a specific use. Irreversible and irretrievable commitments of resources can sometimes be compensated for by the provision of similar resources with substantially the same use or value.

Under the proposed action only a portion of the site would be required for the actual construction of the USP and FPC. Resources consumed as a result of the development of the correctional facility would be offset by the creation of the facility and the resulting societal benefits. The use of the developed portion of the land could be considered irretrievably committed. The proposed action would also require the commitment of various construction materials, including cement, aggregate, steel, asphalt, and lumber. There is the potential, however, that these materials could be recycled at some point in the future; therefore, they may not be an irreversible or irretrievable commitment of resources.

The proposed action would also require the consumption of fossil fuels and electrical energy during both the construction and operation of the facility and would be considered an irretrievable commitment of these resources.

Costs associated with roadway and utility improvements to serve the site are not precisely known at this time; however, these costs would be offset by the direct economic benefits of the total project-related expenditures and the annual operating budget. Over the long term, construction of the proposed facility could result in an increase in the pace of development within Letcher County than would occur if the project were not constructed. Although the nature of such development can be controlled through the application of land use regulations, any induced land development is for all practical purposes, an irreversible and irretrievable commitment of land and materials.


7-2 7.0 Irreversible and Irretrievable Commitments of Resources July 2015



8.0 Cumulative Impacts 8-1 July 2015

8.0 CUMULATIVE IMPACTS

This chapter (1) describes past, present, and reasonably foreseeable future actions relevant to cumulative impacts, (2) analyzes the incremental interaction Alternative 1 may have with other actions, and, (3) evaluates cumulative impacts potentially resulting from these interactions. The definition of cumulative impacts was discussed in Section 3.13.

PAST, PRESENT, AND REASONABLY FORESEEABLE FUTURE ACTION 8.1

This section identifies past, present, and reasonably foreseeable future actions not related to Alternative 1 or Alternative 2 that have the potential to cumulatively impact the resources in the affected environment for proposed action and its regionally affected area. Geographic distribution, intensity, duration, and historical effects of similar activities were considered when determining whether a particular activity may contribute cumulatively and significantly to the impacts of Alternative 1 or Alternative 2 on the resources identified in the EIS. Based on discussions with the economic development leaders for Letcher County development within the county has not been strong and there are very few past, present, or reasonably foreseeable future actions that when combined with the proposed action would result in cumulative impacts to the resources evaluated in this EIS (DePriest 2013). Future projects identified include a new regional airport and Gateway Regional Business Park. In addition to these projects, there are infrastructure and utility projects associated with the proposed action that have the potential to result in cumulative impacts.

Letcher County Airport Project 8.1.1

The airport board has applied to be included in the FAA’s National Plan of Integrated Airport Systems Program and the project qualifies for FAA funding. The Kentucky Department of Aviation funded a Site Selection Study and based on the study a site was identified for development of the airport. The airport board is currently working with landowners to purchase the site. Once the acquisition of property has occurred the airport board would apply to FAA to fund the development of an airport layout plan and environmental assessment. Potential impacts resulting from the project could include land use, topography, geology, and soils, air quality, noise, socioeconomics, traffic, infrastructure and utilities, natural resources and cultural resources. Siting of the airport may have impacts to land use compatibility with adjacent land uses. Excavation and grading activities to prepare the site for development may result in changes and impacts to topography, geology, and soils. Both short- and long-term impacts to air quality could occur as the result of construction and operation activities of the airport. Development of the airport has the potential to result in short-term and long-term impacts to traffic as a result of construction vehicles accessing the site during construction and long-term impacts as a result of increased traffic to area roadways once the airport is operational. Short-term and long-term impacts due to increases in noise would likely result from construction activities and the operation of aircraft. It is anticipated that infrastructure and utilities would have increased demands placed on them during construction as well as operation of the airport. Other impacts that could result due to construction of the airport include cultural and natural resources. Beneficial impacts would be anticipated to the economy of the region due to new jobs and potential tax base.


8-2 8.0 Cumulative Impacts July 2015

Gateway Regional Business Park 8.1.2

The Gateway Regional Business Park is approximately 261 acres (106 hectares) located just north of Payne Gap. Development of the site would have potential impacts to land use, air quality, noise, infrastructure and utilities, and transportation and traffic. The Gateway Regional Business Park has the potential to be incompatible with surrounding land uses; however, Letcher County does not have any zoning ordinances that would regulate development and compatibility. The project also has the potential to have short-term temporary impacts to air quality and noise as a result of construction activities. Infrastructure and utilities would also have the potential to be impacted due to increased demands on potable water, waste water treatment, and solid waste. Additionally, development of the business park would likely increase traffic on U.S. Route 119 and may contribute to impacts to congestion on area roadways.

Infrastructure and Utility Projects 8.1.3

Alternative 1 and Alternative 2 would both require utility companies to upgrade facilities, extend cable, and construct new facilities to provide service to the proposed USP, FPC, and ancillary facilities. These projects would be dependent on the preferred alternative and conducted by the individual utility company. Impacts associated with these projects have the potential to include land use, air quality, noise, soils, natural resources, and cultural resources. The projects have the potential to be incompatible with surrounding land use, result in temporary increases to air emissions and temporary air quality impacts, temporary noise impacts due to construction activities, disturbance of soils that could result in erosion and sedimentation issues, as well as impacts to natural and cultural resources depending on the type and location of the upgrade or new construction, and placement of cable.

Proposed Action 8.1.4

The proposed action would result in conversion of land uses and contribute to incompatibility with adjacent land uses. The proposed action would also contribute to short-term temporary increases to noise and increase local air emissions, as well as have an overall contribution to greenhouse gases (GHGs). The proposed action has the potential to impact transportation and traffic. The proposed action is not anticipated to have impacts to infrastructure and utilities.

As stated in Sections 4.6 and 5.6, there are small emission increases anticipated for all criteria pollutants; however, all increases are considered to be minor adverse impacts. As a result, this cumulative impacts analysis focuses on GHGs. Since individual sources of GHG emissions are not large enough to have an appreciable effect on climate change and the potential effects of proposed GHG emissions on climate change are global by nature, the study area for this aspect is not defined.

GHGs are gases in the Earth’s atmosphere that prevent heat from escaping into space, resulting in climate change as the Earth's surface temperature increases above past levels. GHGs result primarily from the combustion of fossil fuels, and include carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6). EO 13514, Federal Leadership in Environmental, Energy, and Economic Performance, requires federal agencies to inventory and report direct and indirect emissions of GHGs, including those associated with fuel consumption and the purchase of electricity. In addition, facilities with stationary combustion sources must determine applicability of the USEPA’s Greenhouse Gas Reporting Program, as promulgated in 40 CFR Part 98, which requires reporting from facilities that emit 25,000 metric tons CO2 equivalent (CO2e) or more per


8.0 Cumulative Impacts 8-3 July 2015

year from stationary source fuel combustion. Emission sources evaluated in this EIS are associated with construction and site operations. The primary GHG emission associated with these sources is CO2, and to a lesser extent, CH4 and N2O. Emissions of these GHGs are carried forward in the analysis.

GHGs are produced from the burning of fossil fuels, as well as through industrial and biological processes. There are no published NEPA thresholds of significance for GHG emissions resulting from a proposed action and formulation of thresholds is difficult when attempting to identify what level of emissions would substantially contribute to global climate change. The cumulative effects for GHG emissions were evaluated for the proposed construction and subsequent operation activities.

Table 8-1 compares the GHG emissions associated with the proposed construction activities at the Payne Gap site to the U.S. 2011 GHG emissions. The estimated GHG emissions from the proposed construction activities are less than a thousandth of 1 percent of the total GHG emissions generated by the United States in 2011.

Table 8-1. Estimated GHG Emissions from Construction Activities at Payne Gap Site

Year CO2e

(metric tons per year) 1 10,913 2 10,913

Total 21,826 1U.S. 2011 GHG Emissions 6,708.3 x 106 Percent of U.S. 2011 GHG Emissions .00032 Source: USEPA 2013c.

Table 8-2 compares the GHG emissions associated with the proposed construction activities at the Roxana site to the U.S. 2011 GHG emissions. The estimated GHG emissions from the proposed construction activities are less than a thousandth of 1 percent of the total GHG emissions generated by the U.S. in 2011.

Table 8-2. Estimated GHG Emissions from Construction Activities at Roxana Site

Year CO2e

(metric tons per year) 1 4,006 2 4,006

Total 8,012 1U.S. 2011 GHG Emissions 6,708.3 x 106 Percent of U.S. 2011 GHG Emissions .00012 Source: USEPA 2013c.

Table 8-3 compares the GHG emissions associated with the proposed operation of stationary sources (boilers and emergency generators) and staff commuter emissions once the facilities are operational. The estimated GHG emissions from the proposed operations are less than ten thousandth of 1 percent of the total GHG emissions generated by the U.S. in 2011.


8-4 8.0 Cumulative Impacts July 2015

Table 8-3. Estimated GHG Emissions from Operations at Either Site CO2e 1,271 1U.S. 2011 GHG Emissions 6,708.3 x 106 Percent of U.S. 2011 GHG Emissions .000019

Source: USEPA 2013c.

Individual sources of anthropogenic GHG emissions are not large enough to have an appreciable effect on climate change. For this reason, emissions of GHGs from the proposed action alone would not cause appreciable global warming that would lead to climate change. These emissions would increase the atmosphere’s concentration of GHGs, and, in combination with past and future emissions from all other sources, contribute incrementally to the global warming that produces the adverse effects of climate change. Therefore, an appreciable impact on global climate change would, if current predictions are accurate, only occur when proposed GHG emissions combine with other GHG emissions from other man-made activities on a global scale.

Potential Cumulative Impacts 8.1.5

When combined with past, present, and reasonably foreseeable future projects, the proposed action would likely contribute to permanent impacts to land use and transportation, as well as temporary impacts to air quality and noise. However, under the proposed action, land use compatibility issues with adjacent properties would be minimized through the siting of the facility and use of buffer areas to reduce potential incompatibility issues with surround residences and forested/undeveloped areas.

Under the proposed action, the potential impact to traffic would be reduced to a less than significant level with the implementation of mitigation outlined in the Traffic Impact Study. Therefore, while the proposed action may contribute to cumulative impacts, mitigation measures would be in place and the cumulative impact would be considered less than significant.


9.0 References 9-1 July 2015

9.0 REFERENCES

Cardno. 2014a. Enhanced Utilities Report Letcher County, Kentucky. Prepared for Federal Bureau of Prisons. October.

Cardno. 2014b. Historic Architectural Resources Survey for a Proposed Federal Correctional Facility, Letcher County, Kentucky. Prepared for Federal Bureau of Prisons, Washington, D.C. February.

Cardno 2014c. Draft Supplemental Jurisdictional Delineation Payne Gap and Roxana Sites. Prepared for Federal Bureau of Prisons. August.

Copperhead Environmental Consulting. 2015. Desktop Analysis and Habitat Survey for the Indiana Bat (Myotis sodalis), Gray Bat (Myotis grisescens), and Northern Long-eared Bat (Myotis septentrionalis) at two Sites for a Proposed Federal Correctional Facility in Letcher County, KY. Prepared for the Federal Bureau of Prisons. January.

Council on Environmental Quality (CEQ). 1997. Environmental Justice, Guidance Under the National Environmental Policy Act. December 10.

Crouch, Bruce. 2014. Operator, Laurel Ridge Landfill. Personal Communication.

DePriest, Joe. 2013. Economic Development Director, Letcher County. Personal Communication.

Division of Planning. 2011. Kentucky Transportation Cabinet: Traffic Station Counts, Letcher County. February.

Federal Highway Administration. 2006. Highway Traffic Noise: Construction Noise Handbook, Chapter 9. http://www.fhwa.dot.gov/environment/noise/construction_noise/handbook/handbook09.cfm. Last updated July 5, 2011, accessed March 7, 2013.

Fleming Neon Fire Department. 2013. Scott Collins, Captain. Personal Communication.

Fleming Neon Police Department. 2013. Mike Dingus, Chief of Police. Personal Communication.

Hall, L.S., P.R. Krausman, and M.L. Morrison. 1997. The habitat concept and a plea for standard terminology. Wildlife Society Bulletin 25:173-182.

Institute of Transportation Engineers (ITE). 2012. Trip Generation Manual, 9th Edition. Washington, DC.

Jenkins Police Department. 2013. Todd DePriest, Public Safety Director for the City of Jenkins. Personal Communication.

Jenkins Volunteer Fire Station. 2013. Todd DePriest, Public Safety Director for the City of Jenkins. Personal Communication.

Kentucky Department of Environmental Protection (KDEP). 1994. Division of Water: Groundwater Branch. Groundwater Sensitivity Regions of Kentucky. Retrieved July 17, 2013. From http://kgs.uky.edu/kgsweb/download/wrs/sensitivity.pdf.

http://www.fhwa.dot.gov/environment/noise/construction_noise/handbook/handbook09.cfm

http://www.fhwa.dot.gov/environment/noise/construction_noise/handbook/handbook09.cfm


9-2 9.0 References July 2015

KDEP. 2013. Division of Water, Total Maximum Daily Load Program. Retrieved July 17, 2013. From http://water.ky.gov/waterquality/Pages/303dList.aspx.

Kentucky Department of Fish and Wildlife Resources. 2013. Species Information; Species Observations for Letcher County. Retrieved July 22, 2013. From http://fw.ky.gov/kfwis/speciesInfo/countyList.asp?strGroup=3.

Kentucky Geological Survey (KGS). 2013. University of Kentucky, Geologic Information for Letcher County. Retrieved July 17, 2013. From http://kgs.uky.edu/kgsmap/kgsgeoserver/viewer.asp?layoutid=0&startleft=5757559.8080555545&startright=5804478.2108333325&starttop=3562679.1566666653&startbottom=3591845.8233333323&queryzoom=true.

Kentucky Heritage Council (KHC). 2011. Letter from Linda Casebier, Acting Executive Director and State Historic Preservation Officer, to Bridgette Lyles, Site Selection Specialist, Bureau of Prisons, regarding the Architectural Resource Reconnaissance Survey, Letcher County, Kentucky. September 13.

KHC. 2014. Letter from Craig A. Potts, Executive Director and State Historic Preservation Officer, to Issac Gaston, Capacity Planning and Site Selection Branch, Bureau of Prisons, regarding the Historic Architectural Resources Survey, for Proposed Federal Correctional Facility, Letcher County, Kentucky. April 24.

Kentucky Labor Market Information (KYLMI). 2014. Labor Force, Employment and Unemployment for Letcher County, Kentucky in Multiple Time Periods. Retrieved November 5. From https://kylmi.ky.gov/vosnet/analyzer/results.aspx?session=labforce.

Kentucky River Area Development District (KRADD). 2013. Comprehensive Economic Development Strategy Update, FY 2012-2013, Mapping the Progress of the Kentucky River Area Economy.

Kentucky State Nature Preserves Commission. 2013. Kentucky State Nature Preserves Commission, Key for County List Report. April.

Kentucky State Police. 2013. Claude Little, Investigative Lieutenant. Personal Communication.

Kentucky Transportation Cabinet (KYTC). 2012. Traffic Impact Study Requirements.

KYTC. 2014a. Functional Classification. Available on-line at: http://transportation.ky.gov/Planning/Pages/Functional-Classification.aspx. Accessed September 30.

KYTC. 2014b. Traffic Station Counts. Available on-line at: http://transportation.ky.gov/planning/pages/count-maps.aspx. Accessed September 30.

KYTC. 2014c. Truck Weight Limits on State-Maintained Routes. Available on-line at: http://apps.transportation.ky.gov/HIS_Reports/TruckWeightLimitsParam.aspx. Accessed November 6.

KYTC. 2014d. Kentucky Truck Weight Classification. Available on-line at: http://transportation.ky.gov/Planning/Documents/Weight%20Class.pdf. Accessed November 6.

http://water.ky.gov/waterquality/Pages/303dList.aspx

http://fw.ky.gov/kfwis/speciesInfo/countyList.asp?strGroup=3

http://kgs.uky.edu/kgsmap/kgsgeoserver/viewer.asp?layoutid=0&startleft=5757559.8080555545&startright=5804478.2108333325&starttop=3562679.1566666653&startbottom=3591845.8233333323&queryzoom=true



https://kylmi.ky.gov/vosnet/analyzer/results.aspx?session=labforce

http://transportation.ky.gov/Planning/Pages/Functional-Classification.aspx

http://apps.transportation.ky.gov/HIS_Reports/TruckWeightLimitsParam.aspx

http://transportation.ky.gov/Planning/Documents/Weight%20Class.pdf



Letcher County Fire and Rescue. 2013. John Amburgey, EMS Lieutenant. Personal Communication.

Letcher County Sheriff. 2013. Eugene Sloan, Victims Advocate for Letcher County. Personal Communication.

Marshall Miller. 2012a. Existing Conditions: Payne Gap Study Area. May 11.

Marshall Miller. 2012b. Existing Conditions: Roxana Study Area. May 11.

Meade, Robert. 2015. Personal Communication. March.

Midwest Research Institute. 2005. Analysis of the Fine Fraction of Particulate Matter in Fugitive Dust. October 12.

Natural Resources Conservation Service (NRCS). 2013. Websoil Survey. Retrieved July 19, 2013. From http://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx.

Natureserve. 2013a. Explorer: Gray Bat (Myotis grisescens), Ecology and Life History. Retrieved July 19, 2013. From http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Myotis+grisescens.

Natureserve. 2013b. Explorer: Indiana Bat (Myotis sodalis), Ecology and Life History. Retrieved July 19, 2013. From http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Myotis+sodalis.

Occupational Safety and Health Administration (OSHA). 2013. General Industry Digest. OSHA 2201-05R 2013.

Parsons. 2015. Federal Correctional Facility Environmental Impact Statement, Draft Traffic Impact Study. April.

Proximity One. 2014. Demographic Trends 2010-2060. Accessed October 13, 2014. http://proximityone.com.

Sierra Club. 2015. Coal Ash Waste-Beyond Coal. Accessed June 15, 2015. http://content.sierraclub.org/coal/disposal-ash-waste.

Sparkman, Dena. 2014. CEO Whitesburg ARH Hospital. Personal Communication.

TEC, Inc. 2011a. Architectural Resource Reconnaissance Survey, Letcher County, Kentucky. Prepared for Bureau of Prisons, Washington, D.C. August.

TEC, Inc. 2011b. Draft Wetland Identification and Delineation Report, Payne Gap/Lawson Site, Letcher County, Kentucky. Prepared for Federal Bureau of Prisons. August.

TEC, Inc. 2011c. Draft Wetland Identification and Delineation Report, Roxana/Meade Farm, Letcher County, Kentucky. Prepared for Federal Bureau of Prisons. August.

TEC, Inc. 2012. Feasibility Study for Proposed Correctional Facility, Letcher County, Kentucky. Prepared for Federal Bureau of Prisons, Washington, D.C. June.

Transportation Research Board. 2010. Highway Capacity Manual. Fifth Edition. Washington, DC.

http://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx

http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Myotis+grisescens

http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Myotis+sodalis

http://proximityone.com/



University of Kentucky. 2013a. Kentucky Maps. Retrieved July 18, 2013. From http://www.uky.edu/KGS/gis/krgweb/.

University of Kentucky. 2013b. Kentucky Geologic Map Information Service. Retrieved July 18, 2013. From http://kgs.uky.edu/kgsmap/kgsgeoserver/viewer.asp.

U.S. Army Corps of Engineers (USACE). 1987. Corps of Engineers Wetlands Delineation Manual, Wetlands Research Program Technical Report Y-87-1 (online edition).

U.S. Census Bureau. 2000. Table DP-1, Profile of General Demographic Characteristics: 2000. Summary File 1. http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?fpt=table. Accessed November 10, 2014.

U.S. Census Bureau. 2010. Table DP-1, Profile of General Population and Housing Characteristics: 2010. Demographic Profile Data. http://factfinder.census.gov/faces/tableservices/jsf/pages/productview.xhtml?src=CF. Accessed November 10, 2014.

U.S. Census Bureau. 2014a. 2011-2013 American Community Survey 3-Year Estimates, Table DP03, Selected Economic Characteristics. http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?fpt=table. Accessed November 11, 2014.

U.S. Census Bureau. 2014b. 2011-2013 American Community Survey 3-Year Estimates, Table DP04, Selected Housing Characteristics. http://factfinder2.census.gov/rest/dnldController/deliver?_ts=433256505856. Accessed November 5, 2014.

U.S. Census Bureau. 2014c. 2011-2013 American Community Survey 3-Year Estimates, Table DP05, Demographic and Housing Estimates. http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?fpt=table. Accessed November 6, 2014.

U.S. Department of Commerce. 2014. Bureau of Economic Analysis. BEARFACTS Letcher County, Kentucky. http://www.bea.gov/REGIONAL/bearfacts/action.cfm?fips=21133&areatype=21133. Accessed November 6, 2014.

U.S. Environmental Protection Agency (USEPA). 1971. Noise from Construction Equipment and Operations, Building Equipment and Home Appliances.

USEPA. 1982. Guidelines for Noise Impact Analysis. April.

USEPA. 2011. National Ambient Air Quality Standards. From http://www.epa.gov/air/criteria.html.

USEPA. 2013a. My Waters Mapper. Retrieved July 16, 2013. From http://watersgeo.epa.gov/mwm/.

USEPA. 2013b. Region 4: Ground Water Protection, Sole Source Aquifers in the Southeast. Retrieved July 18, 2013. From http://www.epa.gov/region4/water/groundwater/r4ssa.html.

USEPA. 2013c. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990 – 2011. April 12.

http://www.uky.edu/KGS/gis/krgweb/

http://kgs.uky.edu/kgsmap/kgsgeoserver/viewer.asp

http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?fpt=table

http://factfinder.census.gov/faces/tableservices/jsf/pages/productview.xhtml?src=CF



http://factfinder2.census.gov/rest/dnldController/deliver?_ts=433256505856



http://www.bea.gov/REGIONAL/bearfacts/action.cfm?fips=21133&areatype=21133

http://www.epa.gov/air/criteria.html

http://watersgeo.epa.gov/mwm/

http://www.epa.gov/region4/water/groundwater/r4ssa.html



USEPA. 2015a. Coal Combustion Residuals (CCR) –Surface Impoundments with High Hazard Potential Ratings. Retrieved June 15, 2015. From http://www.epa.gov/osw/nonhaz/industrial/special/fossil/ccrs-fs/.

USEPA. 2015b. Coal Combustion Residuals Impoundment Assessment Reports. Retrieved June 15, 2015. From http://www.epa.gov/osw/nonhaz/industrial/special/fossil/surveys2/index.htm.

USEPA 2015c. http://www.epa.gov/radon/ . Retrieved June 1, 2015.

U.S. Fish and Wildlife Service (USFWS). 2010. Species Assessment and Listing Priority Assignment Form. March.

USFWS. 2013. Critical Habitat Mapper. Retrieved July 19, 2013. From http://criticalhabitat.fws.gov/crithab/flex/crithabMapper.jsp?.

Wagoner, Lisa. 2014. Letcher County Schools. Personal Communication.

Western Governors’ Association. 2006. WRAP Fugitive Dust Handbook. Prepared for Western Governors’ Association, Denver, CO, by Countess Environmental, Westlake Village, CA. September 7.

Whitesburg Fire and Rescue. 2013. Benny Bentley, Volunteer Firefighter. Personal Communication.

Whitesburg Police Department. 2013. Garnet Sexton, City Clerk and Treasurer for Whitesburg. Personal Communication.

http://www.epa.gov/osw/nonhaz/industrial/special/fossil/ccrs-fs/

http://www.epa.gov/osw/nonhaz/industrial/special/fossil/surveys2/index.htm

http://www.epa.gov/radon/

http://criticalhabitat.fws.gov/crithab/flex/crithabMapper.jsp


10.0 List of Preparers 10-1 July 2015

10.0 LIST OF PREPARERS

Federal Bureau of Prisons

Thomas Webber, Director Capacity Planning and Construction Branch

Issac Gaston, Site Selection Specialist

Cardno

Cristina Ailes – Public Involvement Specialist B.S. Environmental Science B.A. International Studies Years of Experience: 7

Erika Fuery – Hazardous Materials and Waste M.S. Environmental Science Years of Experience: 15

Lesley Hamilton – Air Quality B.A. Chemistry Years of Experience: 27

Deborah Henson – Project Manager M.S. Geo-environmental Studies Years of Experience: 17

Joanne Lortie – Socioeconomics M.A. Economics Years of Experience: 24

Kathleen Riek – Quality Control B.S. Biology Years of Experience: 21

Kimberly Sebestyen – Archaeological Resources M.A. American Studies Years of Experience: 21

Abby Shoff– GIS Specialist, Graphics B.S. Geographical Information Systems Years of Experience: 2

Lori Thursby – Architectural Resources M. Architectural History Years of Experience: 17

Jill Yamaner-Infrastructure and Utilities M.S. Environmental Engineering Years of Experience: 22

Dale Nicholson-Grading and Excavation Modeling B.S. Civil Engineering Years of Experience: 35

John Feddock-Quality Control Grading and Excavation Modeling M.S. Mining Engineering Years of Experience:

Sam Moore-Roadway Design and Site Grading Years of Experience: 35

Dave McChesney-Cut and Fill Modeling B.S. Mining Engineering Years of Experience: 31


10-2 10.0 List of Preparers July 2015



11.0 Distribution List 11-1 July 2015

11.0 DISTRIBUTION LIST

Federal Elected Officials

Senator Mitch McConnell 317 Russell Senate Office Building Washington, DC 20510

Senator Rand Paul 124 Russell Senate Office Building Washington, DC 20510

Representative Harold Rogers 2406 Rayburn House Office Building Washington, DC 20515

State Elected Officials

Governor Steve Beshear 700 Capitol Avenue, Suite 100 Frankfort, Kentucky 40601

Senator Johnny Ray Turner 849 Crestwood drive Prestonsburg, KY 41653

State Representative John Short 240 Briarwood Lane Mallie, KY 41836

Representative Leslie Combs 245 E Cedar Drive Pikeville, KY 41501

Local Elected Officials

Jim Ward, Letcher County Judge Executive 156 Main Street, Suite 107 Whitesburg, KY 41858

Mayor James Craft 38 East Main Street Whitesburg, KY 41858

Mayor Todd Depriest P.O. Box 568 Jenkins, KY 41537

Keith Adams P.O. Box 5 Jeremiah, KY 41826

Terry Adams Po Box 488 Isom, Kentucky 41824

Edison G. Banks, II 48 East Main Street Whitesburg, KY 41858

Bobby Howard 247 Tunnel Road Whitesburg, Kentucky

Don McCall 156 Main Street Whitesburg, KY 41858

Robin Bowan Watko 27 Della Drive Whitesburg, KY 41858

Jamie Hatton, County Attorney 95 A Main Street Whitesburg, KY 41858


11-2 11.0 Distribution List July 2015

Shela Shortt 181 Shady Drive Whitesburg, KY 41858

Danny Web 6 Broadway Street Whitesburg, KY 41858

John William 146 Maryland Drive Whitesburg, KY 41858

Honorable Samuel T. Wright, III 156 Main Street, Suite 205 Whitesburg, KY 41858

Honorable Kevin R. Mullins 156 Main Street, Suite 101C Whitesburg, KY 41858

Don Wright 2804 Highway 3406 Jenkins, KY 41537

Federal Agencies

US Environmental Protection Agency – EIS Filing Section

Heinz Mueller US Environmental Protection Agency, Region 4 61 Forsyth Street Atlanta, GA 30303

Lee Andrews U.S. Fish and Wildlife Service Kentucky Field Office

330 W Broadway, Suite 265 Frankfort, KY 40601

David Baldridge U.S. Army Corps of Engineers Louisville District 845 Sassafras Creek Road Sassafras, KY 41759

State Agencies

State Clearinghouse

Ronald T. Price Executive Staff Advisor

Office of the Commissioner Department of Environmental Protection 300 Fair Oaks Lane Frankfort, KY 40601

Others

Frank Adams 309 Seco Dr. Seco, KY 41849

Bobby Adams 1797 Highway 343 McRoberts, KY 41835

Larry Adams P.O. Box 111 Isom, KY 41824

Trish Adams

412 Roy Campbell Drive, Suite 100 Hazard, KY 41701

Hettie Adams 251 Pert Creek Rd Whitesburg, KY 41858

Doug Adams 24 Baker Dr Whitesburg, KY 41858

Barbara Adams 69 Adams Ln Redfox, KY 41847

Danny Adams P.O. Box 843 Jenkins, KY 41537

Wade Adams 1168 Rainbow Valley Whitesburg, KY 41858



Larry Adams P.O. Box 1054 Hazard, KY 41702

Paul Adams 63 Arizona Avenue Whitesburg, KY 41858

D Adams 126 Walter Br Rd Isom, KY 41824

Danielle Adams P.O Box 568 Jenkins, KY 41537

Stephen Amber P.O. Box 436 Whitesburg, KY 41858

Emily Anderson 159 Corkwood Ln Mayking, KY 41838

Craig Baily P.O. Box 67 Isom, KY 41824

Shad Baker P.O. Box 204 Jenkins, KY 41537

Marty Baker 181 Susan Cook Dr Whitesburg, KY 41858

Kevin and Courtney Baker 3197 Highway 803 Millstone, KY 41838

Bob Banks 4625 Highway 7 South Letcher, KY 41832

Davis Banks 234 Boney Banks Cemetery Rd Whitesburg, KY 41858

Sally Barto

100 Tennessee Avenue Whitesburg, KY 41858

Danny and Dionne Bates 44 Steelbridge Rd Blackey, KY 41804

Connie Bates 3267 Highway 15 Whitesburg, KY 41858

Wendy Bates 126 Big Shelby Creek Jenkins, KY 41537

Duane Beachey 2670 Highway 1148 Isom, KY 41824

Scottie Billiter P.O. Box 815 Jenkins, KY 41537

Benjamin Blair 53 Log Cabin Dr. Mayking, KY 41837

Teresa Blair P.O. Box 587 Whitesburg, KY 41858

Randy Blair 347 Chissom Rd Jeremiah, KY 41826

Zachary Boggs P.O. Box 974 Pound, VA 24279

Melinda Boggs 334 Highway 3404 Partridge, KY 40862

Daryl Boggs P.O. Box 806 Whitesburg, KY 41858

Anita Bolt 451 Murphy Street NW Norton, VA 24273

Thomas Bornes 98 B & O Hill Jenkins, KY 41537

Chad Bowling 671 Old Long Fork Road Virgie, KY 41572

Tony Bowling

41 Commercial Dr Hazard, KY 41701

Bette Braddock 304 Indian Creek Road Whitesburg, KY 41858

Jeffery Breeding P.O. Box 442 Neon, KY 41840

Tim Breeding P.O. Box 86 Isom, KY 41824

Shirley Breeding P.O. Box 1 Isom, KY 41824

Kinnita Brock 1150 Pert Creek Rd Whitesburg, KY 41858



Henry Brooks P.O. Box 279 Whitesburg, KY 41858

Nancy Brown 18 Tyler Lane Whitesburg, KY 41858

Tracy Brown 16 Tyler Lane Whitesburg, KY 41858

Regina Brown 4380 Highway 7 South Blackey, KY 41804

Roland Brown 1141 Doty Creek Jeremiah, KY 41826

Charlotte Brown 960 Little Dry Fork Whitesburg, KY 41858

Ron Brunty 149 Hiram Bailey Loop Letcher, KY 41832

Dwight Buckley 2530 Lower Pompey Rd Shelbiana, KY 41562

Jack Burkich 79 Mountain View Ave Whitesburg, KY 41858

Theresa Callihan 9886 Highway 931 South Whitesburg, KY 41858

Nancy Campbell 40 Windmill Acres Blackey, KY 41804

William Campbell 31 North Adams Ridge Hazard, KY 41701

Stephanie Cassell 714 Laurel Lane Norton, VA 24273

Sally Caudill 25 Mountain View Ave Whitesburg, KY 41858

Holly Caudill 1119 Highway 1148 Isom, KY 41824

Sandy Caudill P.O. Box 234 Ermine, KY 41818

William Caudill 1936 Carcassonne Rd Blackey, KY 41804

Jill Caudill P.O. Box 560 Whitesburg, KY 41858

Mike and Joy Caudill P.O. Box 831 Whitesburg, KY 41858

David Clark P.O. Box 902 Whitesburg, KY 41858

Sarah Clark P.O. Box 319 101 Chestnut St Berea, KY 40404

Harry Collins

562 Smoot Creek Whitesburg, KY 41858

Jackie Collins 73 El Paso Drive Whitesburg, KY 41858

Johnny Combs 8141 Highway 15 Isom, KY 41824

Rebecca Cook 1956 Highway 931 South Whitesburg, KY 41858

Sandra Cook P.O. Box 336 Mayking, KY 41837

Debbie Cook P.O. Box 1052 Thornton, KY 41855

Heather Corbett P.O. Box 626 Jenkins, KY 41537

Terry Cornett 15844 Highway 160 Linefork, KY 41833

Elwood Cornett 262 Elwood Rd Blackey, KY 41804

Roland Craft P.O. Box 568 Jenkins, KY 41537

Amy Craft P.O. Box 8 Mayking, KY 41837

Amy Crawford P.O. Box 333 Mayking, KY 41837



Sandi Curd P.O. Box 1738 London, KY 40741

Jean Curry 37 Arlington Cirlce Jenkins, KY 41537

Rick Damron 60 Camden Rd Jenkins, KY 41537

Lisa Daniels 131 Summit Dr Pikeville, KY 41501

Carol Day P.O. Box 1106 Whitesburg, KY 41858

Dauphus Day 52 Boggs Hollow Whitesburg, KY 41858

Joe DePriest P.O. Box 186 Jenkins, KY 41530

Todd DePriest P.O. Box 2 Jenkins, KY 41537

Michael Dingus P.O. Box 1224 Jenkins, KY 41537

Jennifer Dixon 168 Emory Ln Blackey, KY 41804

Daniel Dixon 192 Turkey Creek Road Hallie, KY 41821

Harlin Eldridge 215 Scarlett Lane Neon, KY 41840

Hazel Eldridge 172 Breezie Ridge Hallie, KY 41821

Larry Everidge P.O. Box 844 Whitesburg, KY 41858

Nell Fields 12225 Highway 160 Whitesburg, KY 41858

James Fields 966 Tolly Br Hallie, KY 41821

Brian Fieldsong 2641 Highway 588 Whitesburg, KY 41858

Brad and Teresa Fleming P.O. Box 1432 Pound, VA 24279

Bea Fleming P.O. Box 432 Pound, VA 24279

Dennis Fleming P.O. Box 280 Whitesburg, KY 41858

Paul Fleming P.O. Box 88 Jenkins, KY 41537

Nancy Fleming P.O. Box 88 Jenkins, KY 41539

Charles Frazier 60 Chandler Dr. Hallie, KY 41821

Doris Jean Frazier 98 Letcher Ave Whitesburg, KY 41858

Alfred Fysste P.O. Box 428 Isom, KY 41840

Chris Gang 557 Burlew Dr Charleston, WV 25302

Deborah Gibson 337 Highway 3401 Whitesburg, KY 41858

Codell Gibson 533 Coperhead Lane Ermine, KY 41815

Emily Gillespie 373 Henry St Appalachia, VA 24216

Peggy Green P.O. Box 263 Jenkins, KY 41537

Michelle Griffin P.O. Box 304 Mayking, KY 41837

Glenna Halcomb 200 Noras Road Cornettsville, KY 41731

David Halcomb 322 Sackett Loop Whitesburg, KY 41850



Brad Hall 3249 N Mayo Trail Pikeville, KY 41501

William and Jennifer Hall 251-C Medical Plaza Whitesburg, KY 41858

Dixie Hall P.O. Box 98 Isom, KY 41824

Eric Hall 190 Misty Branch Neon, KY 41840

April Hall-Ilone P.O. Box 488 Whitesburg, KY 41858

Margaret Hammonds 122 Dow Collins Street Whitesburg, KY 41858

Phillip Hampton P.O. Box 2314 Whitesburg, KY 41858

Robert Hares P.O. Box 563 Jenkins, KY 41537

Crystal Hart P.O. Box 44 Mayking, KY 41837

Jill Hatel P.O. Box 412 Isom, KY 41824

Douglas and Alice Hayes 20 Bayview Dr. Jenkins, KY 41537

Gabrielle Helle 150 Rainbow Dr Whitesburg, KY 41858

Jon Henrikson 3128 Highway 3408 Blackey, KY 41804

Jarrad Hipps 24 Frazier Ave Whitesburg, KY 41858

Connie Hogg 8371 Highway 160 Whitesburg, KY 41858

Angie Holbrook P.O. Box 223 Eolia, KY 40826

Sheila Holbrook P.O. Box 293 Neon, KY 41840

Robert Holcomb 9538 Highway 15 Isom, KY 41824

Zachary Honeycutt 2438 Craft Culley Rd Ermine, KY 41815

Caleb Howard 15 Frazier Ave Whitesburg, KY 41858

Henry Hughes 700 College Road Cumberland, KY 40823

Danny and Nancy Ingram 11638 Highway 160 Whitesburg, KY 41858

James Ison P.O. Box 149 Isom, KY 41824

Patricia Ison 271 Stallard Road Whitesburg, KY 41858

Kendall and Carol Ison 5431 Highway 931 South Whitesburg, KY 41858

Sherwood and Rhoda Ison Highway 522 Totz, KY 40870

Eliza Jane P.O. Box 265 Jenkins, KY 41537

James Johnson 953 Sorgon Road Whitesburg, KY 41815

Brian Johnson P.O.Box 1201 Jekins, KY 41537

Tonya Johnson 340 Tyler Ln Whitesburg, KY 41858

Elizabeth Jones 252 Fairview Ln Neon, KY 41840

Ellis Keyes 240 Hospital Road Whitesburg, KY 41858

James Kincaid P.O. Box 105 Roxana, KY 41804



Sandra Kincer P.O. Box 202 Jenkins, KY 41537

Robin and Dwayne Kincer P.O. Box 183 Jenkins, KY 41537

G. Kincer P.O. Box 1202 Jenkins, KY 41537

Brenda Kincer 243 Heritage Drive Whitesburg, KY 41858

Larry King 1556 Highway 550 East Hindman, KY 41822

Amelia Kirby 1356 Jenkins Rd Whitesburg, KY 41858

R.F. & Edna Kiser 559 Bill Moore Br. Whitesburg, KY 41858

Melissa Knight 82 Improvement Branch Jenkins, KY 41537

Jeanette Ladd P.O. Box 261 Cromona, KY 41810

Margaret Lewis P.O. Box 535 Jenkins, KY 41537

Shawn Lind 4091 Highway 805 Jenkins, KY 41537

John Lindon 210 Apple Ridge Lane Hazard, KY 41701

Dewey Little P.O. Box 43 Pine Top, KY 41731

Shane Lyle 801 Corporate Dr Lexington, KY 40503

Bridgette Madden 1108 Racetrack Holw Whitesburg, KY 41858

Royce Maggard Jr. 70 Morris Dirve Whitesburg, KY 41858

Roger Martin 2743 Highway 7 South Dena , KY 41859

Ricky Mason 588 Stinking Branch Thornton, KY 41855

Josh May P.O. Box 18 Mayking, KY 41837

Jim and Karen McAuley 87 Kona Dr Whitesburg, KY 41858

Bennie McCall P.O. Box 646 Neon, KY 41840

James McDannel 116 Vermillion Ave Whitesburg, KY 41858

Roger and Geraldine McDonald 170 Virginia Ave Whitesburg, KY 41858

Eugene Meade 19 Fields Cliff Whitesburg, KY 41858

Robert Meade 11010 Highway 160 Whitesburg, KY 41858

Shelia Meade P.O. Box 316 Whitesburg, KY 41858

Eddie Meade 2 Stevens Fork Deane, KY 41812

Twyla Messer 219 Yellow Mt. Rd Leburn, KY 41831

Delena Miller 9145 Highway 931 S. Whitesburg, KY 41858

Belinda Morris 493 Highway 3404 Partridge, KY 40862

Annette Napier 917 Perry Park Road Hazard, KY 41701

Lisa Narramore 26 Pine St Whitesburg, KY 41858

Durward & Deborah Narramore 71 Elm St Jenkins, KY 41537



Paul Nesbitt 227 North Upper St Lexington, KY 40507

Freddy Oakes P.O. Box 1102 Thornton, KY 41855

Stanley Osborne 3374 Highway 317 Jackhorn, KY 41825

Leslie Parsons 1771 Highway 931 North Whitesburg, KY 41858

Paul Parsons 1771 Highway 931 North Whitesburg, KY 41858

Ike Patterson 166 Long Ave Whitesburg, KY 41858

James and Rhonda Perry P.O. Box 197 Lynch, KY 40855

Rodney Pigman 71 Darcas Branch Whitesburg, KY 41858

Susan Polis 843 Highway 317 Isom, KY 41840

Lona Leigh Pomraning 134 Ohio St Whitesburg, KY 41858

Gary and Rita Pratt 187 Main Street Whitesburg, KY 41858

Maxine Quillen 77 Sydney Dr Whitesburg, KY 41858

Stephen Raher 1120 N.W. Couch Street 10th Floor Portland, OR 97209-4128

Tarence Ray 260 Main Street, Apt B Whitesburg, KY 41858

JoAnn Redmond P.O. Box 311 Mayking, KY 41837

Cathy Rose 2792 Highway 3406 Jenkins, KY 41537

Elizabeth Sanders 1348 Jenkins Road Whitesburg, KY 41858

Janet Sandlin P.O. Box 834 Hazard, KY 41702

Charles Saxton 412 Solomon Road Whitesburg, KY 41858

Ann Sayer 50 Twin Creek Drive Eolia, KY 40826

Belinda Selton 41 Solomon Rd Whitesburg, KY 41858

David and Linda Setzer 76 Texas Avenue Whitesburg, KY 41858

Michael Sexton 3703 Thornton Rd Thornton, KY 41855

Lovell Sexton 115 Cobra Lane Whitesburg, KY 41858

Jeannie Sexton 395 Sunset View Loop Mayking, KY 41837

Charles and Belinda Sexton 412 Solomon Road Whitesburg, KY 41858

Sybil Shell 20 Autumn Winds Lane Whitesburg, KY 41858

Michael Shepherd 24 Brett Dr. Whitesburg, KY 41858

Susan Short 255 Highway 1087 East Leburn, KY 41831

Caleb Short 200 Alaska Ave, Apt 223 Whitesburg, KY 41858

Carl Shoupe P.O. Box 185 Benham, KY 40807

Robert Shubert 72 Goodwater Circle Jenkins, KY 41537

Eugene Slone 122 Company Br Ermine, KY 41815



Sharon Smallwood 84 Hummingbird Ln Jenkins, KY 41537

Crystal Smallwood P.O. Box 552 Jenkins, KY 41537

Kyle Smith 2438 Highway 2035 Whitesburg, KY 41858

Ada Smith P.O. Box 18 376 Sophia Dr Mayking, KY 41837

Nathan Snowden 14 Dye Addition Whitesburg, KY 41858

Juanita Spangler 202 Frogpond Lane Whitesburg, KY 41858

Duran/Dena Sparkman 99 Royal Melbourne Ln Jenkins, KY 41537

Major Sparks 440 Foothills Rd Whitesburg, KY 41858

Marjorie Sparks 874 Highway 3406 Mayking, KY 41837

Paul Stambaugh 230 Chopping Branch McRoberts, KY 41835

Howard Stanfill P.O. Box 363 Blackey, KY 41804

James Stephens P.O. Box 299 Jenkins, KY 41537

Amanda Stunp 600 Highway 3408 Blackey, KY 41858

Stacey Sturgill P.O Box 776 Lynch, KY 40855

Calvin Tackett 40 Main Street Whitesburg, KY 41858

Michael Thornsberry 7266 Highway 582 Pine Top, KY 41843

Lisa Tidal 18 Collier Court Whitesburg, KY 41858

Tanya Turner P.O. Box 463 Whitesburg, KY 41858

Freda Turnmyre 11984 Highway 805 Jenkins, KY 41537

Priscilla Tyler 52 Tyler Ln Whitesburg, KY 41858

Grace Walters 519 Lakeside Dr. Jenkins, KY 41537

Katie and Marlene Walters 350 Ironwood Dr Hallie, KY 41821

Jim Ward P.O. Box 630 Whitesburg, KY 41858

Anthony Warlick 2928 Highway 343 Mc Roberts, KY 41835

Thomas Watko 27 Della Drive Whitesburg, KY 41858

Ken Watts 180 Old Dixon Rd Blackey, KY 41804

Earnest Watts 75 Watts Dr Cornettsville, KY 41731

Bonnell Watts 247 Croses Br. Letcher, KY 41832

Deborah Watts P.O. Box 74 Jenkins, KY 41537

Jenna Watts P.O. Box 34 Whitesburg, KY 41858

Tyler and Linda Watts 310 Old Dixon Road Blackey, KY 41804

Freddie Watts 310 Old Dixon Road Blackey, KY 41804

Ricky Whitaker 820 Tolby Branch Hallie, KY 41821



Ivan Whitaker 9024 Highway 588 Roxana, KY 41858

Mary Whitaker 5442 Highway 1103 Hallie, KY 41821

Marion Whitaker 481 C. Hill Rd. Cornettsville, KY 41731

Larry and Betty Whitaker 236 Scarlett Lane Neon, KY 41840

Charles and Tina Whitaker P.O. Box 217 Cromona, KY 41810

Pamela White P.O. Box 493 Jenkins, KY 41357

Pam White P.O. Box 493 Jenkins, KY 41537

Shellie Williams P.O. Box 23 Whitesburg, KY 41858

Brady Wilson P.O. Box 444 Ermine, KY 41815

Jennifer Wright P.O. Box 255 Mayking, KY 41838

Brian Wright 227 Low Gap Branch Isom, KY 41824

Mitchell Wright P.O. Box 9 Isom, KY 41824

Donald and Mary Wright 2804 Highway 3406 Jenkins, KY 41537

Heather Yates 155 Barton Branch Partridge, KY 40862

Mark Young P.O. Box 45 McRoberts, KY 41835

Mark and Deborah Young 279 Wintergreen Drive McRoberts, KY 41835

Fred Young 1117 Highway 343 Neon, KY 41840

Don and Melissa Young 1589 Hwy. 343 Neon, KY 41840

LOCAL AGENCIES

Economic Development Commission Joe DePriest Box 186 Jenkins, KY. 41437

Letcher County Planning Commission Box 370 Whitesburg, KY. 41858

Letcher County Emergency Management 156 Main Street, Suite 107 Whitesburg, KY 41858

Libraries

Harry M. Caudill Memorial Library 220 Main Street Whitesburg, KY 41858

Blackey Public Library 295 Main St. Loop Blackey, KY 41804

Jenkins Public Library 9543 Highway 805 Jenkins, KY 41537

Lillian Webb Memorial Library 1049 Highway 317 Neon, KY 41840


Appendix A A-1 July 2015

APPENDIX A AGENCY COORDINATION


A-2 Appendix A July 2015


STEVEN l. 8ESHEAR

GOVERNOR

April 24, 2014

Issac Gaston

TOURISM, ARTS AND HERITAGE CABINET KENTUCKY HERITAGE COUNCIL

BoB STEWART

SECRETARY

CRAIG A. POTTS

THE STATE HISTORIC PRESERVATION OFFICE 300 WASHINGTON STREET

FRANKFORT,KENTUCKY40601 PHONE(502)564-7005

FAX(502)564-5820 www.heritage.ky.gov

EXECUTIVE DIRECTOR AND STATE HISTORIC PRESERVATION OFFICER

United States Department of Justice Federal Bureau of Prisons Capacity Planning and Site Selection Branch 320 First St. NW Washington, DC 20534

Re: Historic Architectural Resources Survey for Proposed Federal Correctional Facility, Letcher County, Kentucky

Dear Mr. Gaston:

On March 27, we received the above referenced report for review and comment. Six historic resources (LR-149 through 153 and LR-188) were evaluated. None ofthe sites are considered eligible for listing in the National Register of Historic Places, and the consultant recommends no further work. We concur with the results of the survey.

If you have questions regarding these comments, please contact Jill Howe of my staff at 502-564-7005, ext. 121.

CP:jh

KentuckyUnbridledSpirit.com

Sincerely,

CZ>~I?K..-Craig A. Potts Executive Director and State Historic Preservation Officer

-ventu~ ~~UNBRIDLED SPIRIT'!/. An Equal Opportunity Employer M/F/D

United States Department of the Interior FISH AND WILDLIFE SERVICE

Kentucky Ecological Services Field Office 330 West Broadway, Suite 265

Frankfort, Kentucky 40601 (502) 695-0468

August 7, 2014

Ms. Deborah Henson Cardno Tec 18 S. George Street, Suite 400 York, PA 17401

Re: FWS 2013-B-0627; Federal Bureau of Prisons; proposed federal penitentiary; located in Letcher County, Kentucky

Dear Ms. Henson:

Thank you for the opportunity to provide comments on the above-referenced project. The U.S. Fish and Wildlife Service (Service) has reviewed this proposed project and offers the following comments in accordance with the Endangered Species Act of 1973 (87 Stat. 884, as amended; 16 U.S.C. 1531 et seq.) and the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661 et seq.). This is not a concurrence letter. Please read carefully, as further consultation with the Service may be required.

In accordance with the provisions of the Fish and Wildlife Coordination Act, the Service has reviewed the project with regards to the effects the proposed actions may have on wetlands and/or other jurisdictional waters. We recommend that project plans be developed to avoid impacting wetland areas and/or streams, and reserve the right to review any required federal or state permits at the time of public notice issuance. The U.S. Army Corps of Engineers should be contacted to assist you in determining if wetlands or other jurisdictional waters are present or if a permit is required.

In accordance to section 7 of the ESA, the Service must evaluate the potential for all the direct, indirect, and cumulative effects of a proposed project on federally listed species. This includes effects of any "interrelated actions" that are part of a larger action and depend on the larger action for their justification and "interdependent actions" that have no independent utility apart from the action under consideration. Please include information about all of the potential impacts associated with the proposed project, including those from interrelated or interdependent actions (e.g.; utilities, etc.) and future actions that are reasonably certain to occur as a result of the proposed project.

In order to assist you in determining if the proposed project has the potential to impact protected species we have searched our records for occurrences of listed species within the vicinity of the proposed project. Based upon the information provided to us and according to our databases, we believe that the following federally listed species have the potential to occur within the project vicinity:

Group Species Common name Legal* Status

Mammals Myotis sodalis Indiana bat E

Myotis grisescens gray bat E

Myotis septentrionalis northern long-eared bat P

Fishes Etheostoma sagitta spilotum Kentucky arrow darter C * Key to notations: E - Endangered, 7' - Threatened P - Proposed, C - Candidate, CH - Critical Habitat

We must advise you that collection records available to the Service may not be all-inclusive. Our database is a compilation of collection records made available by various individuals and resource agencies. This information is seldom based on comprehensive surveys of all potential habitats and thus does not necessarily provide conclusive evidence that protected species are present or absent at a specific locality.

Indiana bat The entire state of Kentucky is within the range of the Indiana bat; (1) caves, rockshelters, and abandoned underground mines provide suitable wintering habitat for the Indiana bat; and (2) forested areas provide suitable summer roosting and foraging habitat for the Indiana bat. In order to address the concerns and be in compliance with the ESA, we have the following recommendations relative to potential direct and/or indirect effects as a result of impacts to the habitats listed above:

(1) During hibernation, the Indiana bat prefers limestone caves, sandstone rockshelters, and abandoned underground mines with stable temperatures of 39 to 46 degrees F and humidity above 74 percent but below saturation. Prior to hibernation, Indiana bats utilize the forest habitat up to five miles from the hibernacula to feed and roost until temperatures drop to a point that forces them into hibernation. This "swarming" period is dependent upon weather conditions and lasts from about September 15 to about November 15. This is a critical time for Indiana bats, since they are acquiring additional fat reserves and mating prior to hibernation.

Based on the presence of numerous caves, rock shelters, and underground mines in Kentucky, we believe that it is reasonable to assume that other caves, rock shelters, and/or abandoned underground mines may occur within the project area, and, if they occur, they could provide winter habitat for Indiana bats. Therefore, we recommend that the project proponent conduct a phase 1 winter hibernacula habitat assessment following the March 15, 2014 "Supplemental Indiana bat survey guidance for Kentucky." This assessment should identify any caves, rock shelters, and underground mines and assess their potential as suitable Indiana bat hibernacula. Depending on the results of the habitat assessment, subsequent bat presence/absence surveys may be necessary to determine if the species is using a feature as a hibernaculum. These presence/absence surveys must be conducted between September 1 and October 31 or April 1 and April 21 following the protocol found in the guidance document cited above.

(2) The Indiana bat utilizes a wide array of forested habitats, including riparian forests, bottomlands, and uplands for both summer foraging and roosting habitat. Indiana bats typically roost under exfoliating bark, in cavities of dead and live trees, and in snags (i.e., dead trees or dead portions of live trees). Trees in excess of 16 inches diameter at breast

2

height (DBH) are considered optimal for maternity colony roosts, but trees in excess of 9 inches DBH appear to provide suitable maternity roosting habitat. Male Indiana bats have been observed roosting in trees as small as 5 inches DBH.

We recommend that the project proponent design or modify the proposed project to eliminate or reduce impacts to suitable Indiana bat habitat, thus avoiding impacts. A habitat assessment may useful in determining if suitable Indiana bat summer roosting or foraging habitat is present in the action area of the proposed project. If suitable habitat removal cannot be avoided, the following are the typical options available to address potential impacts to the species:

• The project proponent survey the project site to determine the presence or likely absence of Indiana bats within the project area in an effort to determine if potential effects are likely. A qualified biologist who holds the appropriate collection permits for the Indiana bat must undertake such surveys in accordance with our most current survey guidance. If any Indiana bats are identified, we would request written notification of such occurrence(s) and further coordination and consultation.

• The project proponent can request formal section 7 consultation through the lead federal action agency associated with the proposed project. To request formal consultation, the project proponent would need to submit a Biological Assessment that describes the action and evaluates the effects of the action on the listed species in the project area. After formal consultation is initiated, the Service has 135 days to prepare a Biological Opinion that analyzes the effects of the action on the listed species and recommends strategies to minimize those effects.

• The project proponent may provide the Service with additional information through the informal consultation process, prepared by a qualified biologist, that includes site-specific habitat information and a thorough effects analysis (direct, indirect, and cumulative) to support a "not likely to adversely affect" determination. "I he Service will review this and decide if there is enough supporting information to concur with the determination.

• The project proponent may choose to assume presence of the species in the project area and enter into a Conservation Memorandum of Agreement (MOA) with the Service to account for the incidental take of Indiana bats. By entering into a Conservation MOA with the Service, Cooperators gain flexibility with regard to the removal of suitable Indiana bat habitat. In exchange for this flexibility, the Cooperator provides recovery-focused conservation benefits to the Indiana bat through the implementation of minimization and mitigation measures that are described in the Indiana Bat Mitigation Guidance for the Commonwealth of Kentucky. For additional information about this option, please notify our office.

The Payne Gap / Lawson site is in potential Indiana bat habitat; all of the options listed above are appropriate for addressing potential impacts to the species at this site. Because the Roxana site is in known "Pl/P2 swarming" habitat, we already know that the species is present in the proposed project area, and, therefore, further surveys are not necessary. Impacts to the species at the Roxana site should be addressed by using one of the last three bullet points listed above.

3

Gray bat Gray bats roost, breed, rear young, and hibernate in caves year round. They migrate between summer and winter caves and will use transient or stopover caves along the way. Gray bats eat a variety of flying aquatic and terrestrial insects present along streams, rivers, and lakes. Low-flow streams produce an abundance of insects and are especially valuable to the gray bat as foraging habitat. For hibernation, the roost site must have an average temperature of 42 to 52 degrees F. Most of the caves used by gray bats for hibernation have deep vertical passages with large rooms that function as cold air traps. Summer caves must be warm, between 57 and 77 degrees F, or have small rooms or domes that can trap the body heat of roosting bats. Summer caves are normally located close to rivers or lakes where the bats feed. Gray bats have been known to fly as far as 12 miles from their colony to feed.

Because we have concerns relating to the gray bat on this project and due to the lack of occurrence information available on this species relative to the proposed project area, we have the following recommendations relative to gray bats.

• Based on the presence of numerous caves, rock shelters, and underground mines in Kentucky, we believe that it is reasonable to assume that other caves, rock shelters, and/or abandoned underground mines may occur within the project area, and, if they occur, they could provide winter/summer habitat for gray bats. Therefore, we would recommend that the project proponent survey the project area for caves, rock shelters, and underground mines. Additional evaluation and/or surveys may be necessary if suitable gray bat hibernacula and/or roosting habitat exists in the action area of the proposed project.

• Sediment Best Management Practices (BMPs) should be utilized and maintained to minimize siltation of the streams located within and in the vicinity of the project area, as these streams represent potential foraging habitat for the gray bat.

Northern long-eared bat The northern long-eared bat was proposed for federal listing under the ESA on October 2, 2013. The Service has extended the deadline for the final determination to April 2, 2015. Both proposed project sites are located in "known summer" northern-long-eared bat habitat. During the summer, northern long-eared bats typically roost singly or in colonies in a wide-variety of forested habitats, where they seek shelter during daylight hours underneath bark or in cavities/crevices of both live trees and snags, including relatively small trees and snags that are less than 5 inches in diameter at breast height (DBH). Northern long-eared bats have also been documented roosting in man-made structures (i.e., buildings, barns, etc.) during the summer. According to current winter occurrence data, northern long-eared bats predominately winter in hibernacula that include caves, tunnels, and underground mine passages.

Although species proposed for listing are not afforded protection under the ESA, when a species is listed, the prohibitions against jeopardizing its continued existence and unauthorized take are effective immediately, regardless of an action's stage of completion. Therefore, to avoid significant project delays, we recommend that the project proponent evaluate and address potential impacts to northern long-eared bat summer habitat and winter habitat that is present in the action area of the proposed project.

4

Kentucky Arrow Darter The Kentucky arrow darter is a rather large, brightly colored darter that is restricted to the upper Kentucky River basin in eastern Kentucky. The species' preferred habitat consists of pools or transitional areas between riffles and pools (runs and glides) in moderate to high gradient streams with bedrock, boulder, and cobble substrates. The species' habitat and range have been severely degraded and limited by water pollution from surface coal mining and gas-exploration activities; removal of riparian vegetation; stream channelization; increased siltation associated with poor mining, logging, and agricultural practices; and deforestation of watersheds. A habitat assessment and/or survey may be necessary to determine if impacts to these species are likely as a result of the proposed project.

As a federal candidate species, the Service sufficient information on the biological status and threats of the species to propose it as endangered or threatened under the ESA, but development of a proposed listing regulation is precluded by other higher priority listing activities. Candidate species receive no statutory protection under the ESA. The Service encourages cooperative conservation efforts for these species because they are, by definition, species that may warrant future protection under the ESA. Addressing the needs of Kentucky arrow darter before the regulatory requirements associated with a listed threatened or endangered species come into play, would allow future developers, landowners, and other entities greater management flexibility to stabilize or restore the species and its habitat for future projects. In addition, as such threats are reduced and populations are increased or stabilized, priority for listing can be shifted to those species in greatest need of the ESA's protective measures. Ideally, sufficient threats can be removed to eliminate the need for listing.

Presence/absence surveys would provide additional information regarding the likelihood that the proposed project would impact Kentucky arrow darter. Surveys would not be necessary if habitat assessments, especially specific conductivity measurements, supported that suitable habitat does not exist in the action area of the proposed project.

Thank you again for your request. Your concern for the protection of endangered and threatened species is greatly appreciated. If you have any questions regarding the information that we have provided, please contact Jessi Miller at (502) 695-0468 extension 104.

Sincerely,

Virgil Lee Andrews, Jr. Field Supervisor

5

STEVEN l. BESHEAR

GOVERNOR

,.. w TOURISM, ARTS AND HERITAGE CABINET

KENTUCKY HERITAGE COUNCIL

8os STEWART

SECRETARY

THE STATE HISTORIC PRESERVATION OFFICE 300 WASHINGTON STREET

FRANKFORT, KENTUCKY 40601 PHONE(502)564-7005

FAX(502)564-5820 www.heritage.ky.gov

December 22, 2014

CRAIG A. POTTS

EXECUTIVE DIRECTOR AND

STATE HISTORIC PRESERVATION OFFICER

Mr. Issac Gaston, Site Selection Specialist Federal Bureau of Prisons 320 First Street NW Washington, DC 20534

Re: Addendum Phase I Archaeological Survey for the Federal Bureau of Prisons Proposed United States Penitentiary and Federal Prison Camp, Letcher County Kentucky, by Kimberly Sebestyen and Steven Brann (Cardno, Inc).

Dear Mr. Gaston:

Thank you for your correspondence regarding the above referenced report for an archaeological survey conducted in Letcher County, Kentucky for the proposed United States Penitentiary and Federal Prison Camp project. The survey found no evidence of cultural resources. Therefore, the author concluded that the project will have no adverse effect on cultural resources that are potentially eligible for listing on the National Register of Historic Places. I concur with the author's findings. Therefore, in accordance with 36CFR Part 800.4 (d) of the Advisory Council's revised regulations our finding is that there are No Historic Properties Present within the undertaking's area of potential impact. Therefore, we have no further comments and responsibility to consult with the Kentucky State Historic Preservation Officer under the Section 106 review process on this project is fulfilled.

Should you have any questions, feel free to contact Yvonne Sherrick of my staff at 564-7005, ext. 113.

CP:43104 cc. George Crothers, Johnathan Kerr (CRA)

Sincerely,

~~ Craig A. Potts Executive Director and State Historic Preservation Officer

KentuckyUnbridledSpirit.com l(tz!l!!~ An Equal Opportunity Employer M/F/D

From: Branham, Justin L LRLTo: Henson, DeborahSubject: RE: BOP Letcher County EIS (UNCLASSIFIED)Date: Wednesday, June 03, 2015 9:34:12 AM

Classification: UNCLASSIFIEDCaveats: NONE

Deb,Thank you for sending the summary. As mentioned previously, I hope to get out and take a look at those streams when I get a break in the schedule. However, I was reviewing some previously authorized projects in the Roxana area and there was a recent project issued on a gas line project near the old Consol haulroad that we traveled. I believe that the consultant could very well have the scores that you need for the project. Considering my limited time to be out in the field, I'm unsure when I'll be able to check the streams. If you would want to contact the consultant and ask them about their data, I'd be more than glad to pass their contact information along to you. The data is valid because I have already concurred with it. If this is an option for you, just let me know and I'll give you the contact information. If not, then I'll try and schedule a visit over that way when I get a chance.

Justin BranhamTeam Leader / Regulatory SpecialistU.S. Army Corps of Engineers - Louisville DistrictEastern Kentucky Regulatory Office845 Sassafras Creek RoadSassafras, KY 41759Phone: 606-642-3208Email: [email protected] on our Regulatory Services are invited:http://corpsmapu.usace.army.mil/cm_apex/f?p=regulatory_survey

-----Original Message-----From: Henson, Deborah [mailto:[email protected]]Sent: Wednesday, June 03, 2015 9:27 AMTo: Branham, Justin L LRLCc: Scheuerman, Clint; [email protected]: [EXTERNAL] BOP Letcher County EIS

Hi Justin,

Thanks again for taking the time to meet with us on May 19th. We appreciate your input and help with this project. The following is a summary of our meeting:

1) The Bureau is requesting a preliminary JD of the Roxana site based on the findings of the site visit conducted on May 18, 2015, the 2011 Roxana Wetland Report, and the 2014 Wetland Report.

2) The Bureau will conduct mitigation for wetlands at a 2:1 ratio. Currently, there are approximately 2 acres of wetland impacts anticipated which would result in roughly 4 acres of mitigation, which is anticipated to be covered by the in-lieu fee program. Currently, the in-lieu fee program is $45,000 per acre which would result in payment, at existing costs, of approximately $190,000. The Bureau understands that this cost my increase before the project is ready to obtain permits and begin construction activities.

mailto:[email protected]


http://corpsmapu.usace.army.mil/cm_apex/f?p=regulatory_survey


3) Stream mitigation will be covered at a cost per linear foot based on Ecological Integrity Unit Scores (which range from 0.1 to 1.0) for the impacted streams. The Ecological Integrity Unit Score for each stream impacted is multiplied by the linear feet of impact to that stream and then multiplied by $750.00.

4) Based on our discussion, the USACOE will take some data from the streams to assist the Bureau in obtaining the Ecological Integrity Unit Scores for the impacted streams. USACOE asks that a map with the streams labeled be forwarded to aide in this task (map is attached).

5) The project may qualify for a Nationwide Permit 39, if the District Engineer waives the linear feet/acreage threshold.

6) The Bureau will continue coordination with USACOE throughout the course of the project to ensure all permit requirements and mitigation measures are implemented.

If you have any comments or edits to this summary, please let me know and I will revise.

Deborah HensonPROJECT MANAGERGOVERNMENT SERVICES DIVISIONCARDNO

Office (+1) 717-547-6278 Mobile (+1) 717-433-7550 Fax (+1) 717-547-6357 Address 145 Limekiln Road, Suite 100, New Cumberland, PA 17070Email [email protected] <mailto:[email protected]> Web www.cardno.com <http://www.cardno.com>

Celebrating 70 Years of Shaping the Future - 1945 - 2015 <http://www.cardno.com/en-us/AboutUs/Pages/70-years-of-Shaping-the-Future.aspx>

This email and its attachments may contain confidential and/or privileged information for the sole use of the intended recipient(s). All electronically supplied data must be checked against an applicable hardcopy version which shall be the only document which Cardno warrants accuracy. If you are not the intended recipient, any use, distribution or copying of the information contained in this email and its attachments is strictly prohibited. If you have received this email in error, please email the sender by replying to this message and immediately delete and destroy any copies of this email and any attachments. The views or opinions expressed are the author's own and may not reflect the views or opinions of Cardno.



http://www.cardno.com/

http://www.cardno.com/en-us/AboutUs/Pages/70-years-of-Shaping-the-Future.aspx


From: Branham, Justin L LRLTo: Deborah HensonSubject: RE: Letcher County EIS (UNCLASSIFIED)Date: Friday, June 26, 2015 9:30:26 AM


No. That would be it. I will be working up the JD request and getting you a JD letter back to you. It won't really affect the EIS at all but it will verify your delineation.

Justin BranhamTeam Leader / Regulatory SpecialistU.S. Army Corps of Engineers - Louisville DistrictEastern Kentucky Regulatory Office845 Sassafras Creek RoadSassafras, KY 41759Phone: 606-642-3208Email: [email protected] on our Regulatory Services are invited:http://corpsmapu.usace.army.mil/cm_apex/f?p=regulatory_survey

-----Original Message-----From: Deborah Henson [mailto:[email protected]]Sent: Friday, June 26, 2015 9:26 AMTo: Branham, Justin L LRLSubject: [EXTERNAL] Letcher County EIS

Good morning Justin,

I just received the stream data and mitigation calculations from James. We will be submitting those ASAP. I have included the mitigation in the Final EIS. The Bureau will be reviewing the Draft FEIS over the next two weeks, so if you have any comments on the mitigation please let me know and we will include in the Final EIS before it goes out for public review. At this point is there anything else you need prior to the release of the Final EIS?

Thanks,

Deb

Deborah HensonPROJECT MANAGERGOVERNMENT SERVICES DIVISIONCARDNO

Office (+1) 717-547-6278 Mobile (+1) 717-433-7550 Fax (+1) 717-547-6357 Address 145 Limekiln Road, Suite 100, New Cumberland, PA 17070Email [email protected] <mailto:[email protected]> Web www.cardno.com



http://corpsmapu.usace.army.mil/cm_apex/f?p=regulatory_survey



From: Deborah HensonTo: "Miller, Jessica"Subject: RE: FW: Letcher County Indiana and Northern Long-Eared Bat MitigationDate: Tuesday, June 30, 2015 1:54:00 PM

Thanks Jessi. I will make sure that is clear in the mitigation section of the FEIS. Deborah HensonPROJECT MANAGER GOVERNMENT SERVICES DIVISIONCARDNO Office (+1) 717-547-6278 Mobile (+1) 717-433-7550 Fax (+1) 717-547-6357 Address 145 Limekiln Road, Suite 100, New Cumberland, PA 17070Email [email protected] Web www.cardno.com This email and its attachments may contain confidential and/or privileged information for the sole use of the intended recipient(s). All electronically supplied data must be checked against an applicable hardcopy version which shall be the only document which Cardno warrants accuracy. If you are not the intended recipient, any use, distribution or copying of the information contained in this email and its attachments is strictly prohibited. If you have received this email in error, please email the sender by replying to this message and immediately delete and destroy any copies of this email and any attachments. The views or opinions expressed are the author's own and may not reflect the views or opinions of Cardno.

From: Miller, Jessica [mailto:[email protected]] Sent: Tuesday, June 30, 2015 1:49 PMTo: Deborah HensonSubject: Re: FW: Letcher County Indiana and Northern Long-Eared Bat Mitigation That looks good, Deb. The only other thing that comes to mind is that tree removal during June and July is not covered under the CMOA. Jessi On Fri, Jun 26, 2015 at 9:22 AM, Deborah Henson <[email protected]> wrote:Hi Jessi, I just wanted to follow up on the below email and make sure there is nothing else you need prior to us moving forward with publication of the Final EIS? Thanks,Deb Deborah HensonPROJECT MANAGER GOVERNMENT SERVICES DIVISIONCARDNO Office (+1) 717-547-6278 Mobile (+1) 717-433-7550 Fax (+1) 717-547-6357 Address 145 Limekiln Road, Suite 100, New Cumberland, PA 17070Email [email protected] Web www.cardno.com








From: Henson, Deborah Sent: Friday, June 12, 2015 9:32 AMTo: Jessica Miller ([email protected])Cc: [email protected]: Letcher County Indiana and Northern Long-Eared Bat Mitigation Good morning Jessi,Just a follow up to our May 20, 2015 meeting to discuss mitigation for the Indiana and northern long-eared bat at the Roxana site. Below is the summary of that meeting and subsequent discussions we have had regarding the Roxana site and mitigation. 1) During the May 20 meeting we discussed that approximately 105 acres of summer habitat for the Indian bat and northern long-eared bat would be impacted at the Roxana site. To be covered under the MOA the impacts must be under 100 acres. Subsequently, the impact areas were re-evaluated and impacts will be approximately 92.5 acres. Based on coordination with you on June 11, 2015 you reviewed the map detailing the impact areas and agree that based on this impact assessment, the Roxana site can be covered through the Conservation Memorandum Agreement (CMOA) following the guidance provided in the USFWS's April 2015 Conservation Strategy for Forest Dwelling Bats in the Commonwealth of Kentucky (Conservation Strategy).2) The CMOA will be put in place between the USFWS and the Bureau when construction funds become available. Mitigation will be in place prior to any disturbance to the site would occur.3) Mitigation identified in the CMOA would include payment to the Kentucky Natural Lands Trust which would be placed in the Imperiled Bat Conservation Fund. The mitigation payment would be used to acquire, protect, and manage bat habitat in Kentucky. Based on 2015 rates mitigation would range from approximately $930,00.00 to $1.3 million. Mitigation payment will depend on the time of year the habitat is impacted and rates may change prior to construction funding becoming available.4) Once construction funding is available, the Bureau will meet with USFWS to ensure the CMOA is in place and mitigation requirements are fulfilled prior to any disturbance at the site (excavation, grading, timber removal, etc.).5) Sediment Best Management Practices would be implemented to minimize sediment being carried to streams on site which may be potential foraging habitat for the gray bat. 6) At this time, based on the Preferred Alternative (Roxana), no formal Section 7 consultation is required for the Letcher County EIS project. Should anything change during the development of the final design site plans, the Bureau will notify USFWS to discuss any changes and how they may effect additional studies and mitigation.Please let me know if you concur with this summary or have any additions or questions. Thanks,Deb Deborah HensonPROJECT MANAGERGOVERNMENT SERVICES DIVISION



CARDNO

Office (+1) 717-547-6278 Mobile (+1) 717-433-7550 Fax (+1) 717-547-6357 Address 145 Limekiln Road, Suite 100, New Cumberland, PA 17070Email [email protected] Web www.cardno.com

Celebrating 70 Years of Shaping the Future – 1945 - 2015


--Jessica Blackwood MillerFish & Wildlife BiologistKentucky Field OfficeU.S. Fish & Wildlife Service330 W. Broadway, Suite 265Frankfort, KY 40601Ph: (502) 695-0468 ext. 104Fax: (502) 695-1024




of 1

ENVIRONMENTAL MEETING/TELEPHONE LOG

Date: 3/6/14 Time: 10:15 Meeting Type and Location: Phone Call Recorded by: NA Participant Names and organizations:

Luke DuPont, Cardno TEC; Bruce Crouch Laurel Ridge Landfill Manager

Contact Information: Mr. Crouch Office: 606-864-7996 Discussion Points: Luke DuPont called the Laurel Ridge Landfill, which has a transfer station located in Letcher County and spoke with the Laurel Ridge Manager (Bruce Crouch) Mr. Crouch indicated the Laurel Ridge landfill, which the Letcher County transfer station delivers to, is permitted for an additional 34 years. He further indicated he expects the landfill to take at least that long to reach capacity. He also indicated there is potential for expansion of the existing landfill and they may be able to get an additional 20 years of use from an expansion. Currently the landfill receives approximately 40-50 tons of refuse per day. Action Items or Resolutions: None

of 1



Luke DuPont, Cardno TEC; Mr. Scott Collins, Paramedic and Captain at the Fleming Neon Fire Department

Contact Information: 606-855-7303 Discussion Points: Luke DuPont called the Fleming Neon fire department to ask to ask questions regarding their personnel, jurisdiction, and equipment. He spoke with Mr. Scott Collins, a Captain at the fire department. Mr. Collins indicated the following: There are a total of between 36 firefighters and EMTs at the Fleming Neon Volunteer Fire Station. Sixteen of which are paid full time employees and twenty are volunteers. The station has seven paramedics and eight EMTs. They only have a single station in Fleming Neon and a substation in Whitesburg. Fleming Neon has two fire engines, 10 ambulances, one tanker truck, one rescue truck, one dive trailer for underwater rescue, one ATV for search and rescue. The run four ambulances during the day and two at night. The firefighters run three crews during the day and one at night The station has with all of the towns in Letcher County. He indicated the Payne Gap site has hydrants or hydrants in close proximity. Spoke with Charles Polly regarding additional questions. Mr. Polly, a firefighter and EMT at Fleming Neon indicated they would be open to discussing an MOU and in the event they were to assist with a fire it would not impact operations. He indicated they are close enough to cover Payne Gap; however, Roxana is a 25 minute drive and they would likely be called in under the overarching mutual aid agreement which covers all of Letcher County. Under the mutual aid agreement all fire departments help out when requested. Action Items or Resolutions: None

of 1



Luke DuPont, Cardno TEC; Mr. Mike Dingus, Chief of Police at the Fleming Neon Police Department

Contact Information: 606-855-7900 Discussion Points: Luke DuPont called the Fleming Neon Police Department to ask questions regarding their personnel, jurisdiction, and equipment. He spoke with Mr. Mike Dingus, the Chief of Police for the Fleming Neon Police Department. Mr. Dingus indicated the following: Fleming Neon has three fulltime employees comprised of one police chief and two police officers. In addition they have one volunteer. They have a ratio of citizen to police of 262:1. They would be able to assist the Payne Gap site if required. They are approximately 6 miles from Payne Gap. They provide service 24 hours a day seven days a week, although may have to be dispatched from home. They have a single station in Fleming Neon, three squad cars (one of which is an SUV). They have county wide jurisdiction Action Items or Resolutions: None

of 2



Luke DuPont, Cardno TEC; Todd Depriest Public Safety Director for the City of Jenkins

Contact Information: City Hall (606) 832 4411 Mr. Depriest Cell (606)-634-6958

Discussion Points: Luke DuPont called the Jenkins City Hall to inquire about personnel, equipment, and jurisdiction of the Jenkins’ Police Department and Fire and Rescue and was given Mr. Todd Depriest’s cell phone number. Mr. Depriest is the Public Safety Director for the Town of Jenkins. Mr Depriest indicated the following: Jenkins’ Fire Department There is an average of between 25-28 firefighters at the Jenkins Volunteer Fire Station. In addition, the station has three administrative personnel. All of the firefighters are volunteers and five of them are EMTs. They have 2 stations in Jenkins. The station has 2 fire engines, an 85-foot tower truck, a 65-foot ladder truck, a 2,500 gallon tanker truck, one heavy rescue truck, and an expedition for personnel transport. The station has mutual aid agreements with all other stations in Letcher County and will cover down at another town’s station or assist in firefighting activities. He also indicated that Payne Gap would fall within their jurisdiction. Jenkins’ Police Mr. Depriest also was also knowledgeable about the Jenkins’ police department. He indicated the following: Jenkins has six full time personnel working for the police in Jenkins. Four of them are the actual police, one is the police chief, and the Public Safety Director for the town, Mr. Depriest. He further indicted they are short staffed one person. The ratio of citizens to police officers is approximately 400:1. There is one police station present in Jenkins.

of 2

The station has 8 squad cars. They have 24 hour coverage with the police officers they have on staff. The Jenkins police have county wide jurisdiction in Letcher County, but are seldom asked by the Sheriff Department of the Kentucky State Police to respond to incidents outside of Jenkins. Mr. DePriest believes the Jenkins Police and Fire Departments would be interested in discussing an MOU with the BOP; however, he would have to defer to the Mayor of Jenkins. Additionally, Mr. Depriest does not believe assisting BOP would result in impacts to current operations. Action Items or Resolutions: None

of 1



Luke DuPont, Cardno TEC; Claude Little, Investigative Lieutenant, Kentucky State Police-Hazard Post

Contact Information: 606-435-6069 Discussion Points: Luke DuPont called Mr. Claude Little, an Investigative Lieutenant for the Kentucky State Police, to inquire about personnel, equipment, and jurisdiction for the Kentucky State Police in the vicinity of the BOP proposed action. Mr. Little indicated the following: The Hazard Post covers the southeastern portion of Kentucky and includes five counties to include Letcher County. He indicated that unless called upon by the State Police or the Sheriff’s Office, the local community law enforcement would not assist the state police outside of their respective communities. Due to budget constraints the State Police laid off five officers at the Hazard Post and are subsequently short staffed five officers. They currently have 39 state troopers, 18 dispatchers, three clerks, one custodian, one criminal analyst, and one arson specialist. The SWAT team is not based out of Hazard County. The state police have 39 squad cars, with between 8-10 spares in the event a squad car goes down. They typically do not have anyone on the road between 4 AM to 6 AM. When asked about interest in discussing a possible MOU Mr. Little indicated the State Police would be interested. Additionally, Mr. Little did not believe assisting BOP would impact their operations. Action Items or Resolutions: NA

of 1



Luke DuPont, Cardno TEC; John Amburgey, EMS Lieutenant, Letcher County Fire and Rescue.

Contact Information: 606-633-8058 Discussion Points: Luke DuPont called Mr. John Amburgey, an EMS Lieutenant for Letcher County Fire and Rescue, to inquire about personnel, equipment, and jurisdiction of the Letcher County Fire and Rescue Service. Mr. Amburgey indicated the following: They have 32 firefighters, comprised of 20 paid firefighters and 12 volunteer firefighters. Their jurisdiction is comprised of the southern side of Letcher County. Fifteen of their personnel are EMTs. They have three stations; Jeremiah, Blackey, and Hallie, The have five ambulances, two tanker trucks, and three engines. Roxana is within their jurisdiction. Gary Rodgers, Director of Fire and Ambulance for the Letcher County Fire and Rescue, answered additional questions regarding potential discussion with BOP for an MOU and potential impacts on operations. Mr. Rodgers indicated they would be interested in discussing an MOU and their operations would not be impacted if they needed to assist BOP. Action Items or Resolutions: NA

of 1



Luke DuPont, Cardno TEC; Benny Bentley, volunteer firefighter, Whitesburg Fire and Rescue

Contact Information: 606-633-2126 Discussion Points: Luke DuPont called Mr. Benny Bentley at the Whitesburg Fire and Rescue Service to ask questions about their personnel, equipment, and jurisdiction. Mr. Bentley indicated the following: The fire department has 30 firefighters, 25 volunteer and five paid. In addition they have three administrative personnel. Five of the firefighters are also EMTs. The station has five engines, a boom truck with a snorkel. The station has mutual aid agreements with the rest of the county and would be able to help out on anything in the county if dispatched. Gary Mullins, the Fire Chief, answered additional questions regarding interest in an MOU with the BOP and potential impacts to operation. Mr. Mullins indicated Whitesburg Fire and Rescue would be interested in discussing an MOU and indicated their support of BOP would not impact their operations. Action Items or Resolutions: NA

of 1



Luke DuPont, Cardno TEC; Garnet Sexton, City Clerk and Treasurer for Whitesburg

Contact Information: 606-633-3700 Discussion Points: Luke DuPont called the Ms. Garnet Sexton, the City Clerk and Treasurer for the City of Whitesburg to inquire about personnel, equipment, and jurisdiction for the Whitesburg Police Department. Ms. Sexton indicates the following: There are nine fulltime employees comprised of six police officers, one chief of police, one second in command, and one secretary. They have a citizen to officer ration of 270:1. They are short staffed one police officer. The department has eight squad cars. The department has one police station in Whitesburg. They provide 24 hour coverage seven days a week. The department’s jurisdiction is limited to the county but could assist at both sites if asked to. Ms. Sexton further indicated that she believe the Whitesburg Police Department would be open to an MOU but the Mayor and Chief of Police of Whitesburg would have the final word. Furthermore, she indicated operations may be impacted in the event they needed to assist. She is concerned there may not be enough proper equipment. Action Items or Resolutions: NA

of 1


Date: 3/12/15 Time: 7:00 p.m. Meeting Type and Location: Public Meeting Recorded by: NA

Participant Names and organizations:

Deborah Henson, Cardno Project Manager and Robert Meade, Fire Chief, Kings Creek Volunteer Fire Department

Contact Information: N/A Discussion Points: Mr. Meade discussed with Ms. Henson the ability and willingness of the Kings Creek Volunteer Fire Department to work with the Bureau to develop and MOU to assist the proposed facility if it were constructed at the Roxana site. Mr. Meade indicated the fire department is 1.5 miles from the site. Mr. Meade stated that the fire department has 23 volunteers, one pumper truck and two large tanker trucks. In addition to the 23 volunteers the department has relationships with other local volunteer fire departments and has an agreement among these departments to assist one another. A local paging system allows the numerous volunteer fire departments to request assistance from one another. Mr. Meade indicated that participating in an MOU and providing assistance to the facility in the event of an emergency would not impact the Kings Creek Volunteer Fire Department. Action Items or Resolutions: NA


Appendix B B-1 July 2015

APPENDIX B EXCAVATION AND GRADING CALCULATIONS


B-2 Appendix B July 2015


Cardno MM&A 5480 Swanton Drive Lexington, KY 40509 USA Phone +1 859 263 2855 Fax +1 859 263 2839 www.cardno.com www.cardnomma.com

Australia • Belgium • Canada • Colombia • Ecuador • Germany • Indonesia • Italy • Kenya • New Zealand • Papua New Guinea • Peru • Tanzania • United Arab Emirates • United Kingdom • United States • Operations in 85 countries

October 24, 2014 Mr. Deborah Henson, Project Manager Cardno Government Services Division 145 Limekiln Road, Suite 100 New Cumberland, Pennsylvania 17070

Subject: Revised Earthwork Quantities and Construction Costs; Proposed Federal Correction Facility • Payne Gap and Roxana Sites Cardno MM&A Project No. CARD003

Dear Ms. Henson:

Per your request, Cardno MM&A (Cardno) is providing revised earthwork quantities and

construction costs for the “Proposed Federal Correction Facility (FCF)” in Letcher County, Kentucky. The original document was prepared for the Payne Gap and Roxana sites and published in a report by Marshall Miller & Associates, Inc. (now Cardno MM&A) titled “Geotechnical Feasibility Report dated June 2012.”

Earthwork quantities and construction costs were presented in the 2012 report for both of these sites. The United States Federal Bureau of Prisons (BOP) provided a conceptual plan for the supporting facilities and access roads for the FCF at both the Payne Gap and Roxana sites.

The proposed “cut shading” on the BOP drawing for the Payne Gap site differed from the proposed cut shading in the Cardno 2012 report. There were no adjustments made in the earthwork quantities provided in this letter report related to this difference. The fill slopes for the supporting facilities at Payne Gap and Roxana were designed at 2:1. “Cut” slopes were designed for the two sites at 1:1. Additional geotechnical studies may indicate the cut slopes can be constructed at ½:1 or steeper. Select fill slopes for the access roads at Payne Gap were steeper than 2:1 to accommodate the existing topography. Slopes steeper than 2:1 may require stabilization which was not estimated for this revision.

Cardno determined the best fit for the access roads and supporting facilities relative to the topography present at the two sites.


Cardno Government Services Division October 24, 2014 Page 2

www.cardnomma.com

The unit costs for the construction quantities were based on “RSMeans Cost Data”1 and updated to reflect 2014 costs.

The earthwork quantities were determined for the supporting facilities and added to the quantities previously determined for the Payne Gap FCF. A 25 % swell factor was used for all fill at the site. A site plan depicting the facilities along with the earthwork cut and fills is attached to this letter report as Map No. PG-4 (Revised). The additional parking area and additional spoil fill area shown on the site plan for the Payne Gap site were added to the main building area.

Payne Gap Earthwork Quantities Unit Cost Unit Cost Units Units Cost

Item $/Cubic Meters $/Cubic Yards Cubic Meters Cubic Yards $ Dollars

Soil Excavation $13.08 $10.00 2,136,671 2,794,660 $27,947,657

Rock Excavation $27.47 $21.00 6,206,251 8,117,470 $170,485,715

Structural Fill $3.92 $3.00 1,312,049 1,716,095 $5,143,232

Spoil Fill $1.31 $1.00 9,256,402 12,106,917 $12,125,887

$/Hectare $/Acres Hectare Acres $ Dollars

Clear Mined Area $740 $300 2.7 7 $1,998

Clear Forest Area $19,030 $7,700 85.3 211 $1,623,259

Total $217,327,748

The earthwork quantities were determined for the supporting facilities and added to the quantities previously determined for the Roxana FCF. Due to space limitations at the site and for cut/fill balancing purposes, all material cut will have to be placed as a structural fill. The swell factor for the rock excavation was 25% and the mine spoil was reduced by 10% for the structural fill. The rock elevations at the prison camp were inferred from borings to the south. The actual rock elevations should be confirmed. Constructing the prison camp at different levels could reduce the amount of rock excavation. A site plan depicting the facilities along with the earthwork cut and fills is attached to this letter report as Map No. RX-4 (Revised). Two locations shown as cut in the main building area will require further investigation.

1 Fortier, Robert, PE, Senior Editor, RSMeans Heavy Construction Cost Data, 28th Annual Edition, A Division of Reed Construction Data, LLC, Construction Publishers & Consultants, 2014.

Cardno Government Services Division October 24, 2014 Page 3

www.cardnomma.com

Roxana Earthwork Quantities

Unit Cost Unit Cost Units Units Cost

Item $/Cubic Meters $/Cubic Yards Cubic Meters Cubic Yards $ Dollars

Spoil Excavation $13.08 $10.00 7,037,223 9,204,340 $92,046,877

Rock Excavation $27.47 $21.00 728,809 953,246 $20,020,383

Structural Fill $3.92 $3.00 7,188,790 9,402,582 $28,180,057

$/Hectare $/Acres Hectare Acres $ Dollars

Clear Mined Area $740 $300 32.7 81 $24,198

Clear Forest Area $19,030 $7,700 44.4 110 $844,932

Total $141,116,447

The revised earthwork quantities and construction costs are based on the provided conceptual plan and the analysis of same, as well as published data and information collected during the 2012 Geotechnical Feasibility

Study. Additional geotechnical studies should be conducted to confirm that the earthwork volumes estimated are adequate to meet the quantified material required for structural fills in the final design.

The earthwork quantities were itemized by facility and are presented on the Tables PG-1A and RX-1A attached to this letter report.

We reserve the right to amend our computations, if any additional information becomes available. This revision is furnished as privileged and confidential to the addressee. Release to any other company, concern, or individual is solely the responsibility of the addressee. We appreciate the opportunity to have assisted you with this project.

Sincerely,

W. Dale Nicholson, P.E., P.L.S. Senior Forensic Engineer

for Cardno MM&A Direct Line 859-977-8865 Email: [email protected] WDN/cfn Attachments Map PG-4 (Revised) – “Site Grading – Payne Gap Study Area”

Map RX-4 (Revised) – “Site Grading – Roxana Study Area” Tables PG-1A and RX-1A

c: File/CARD003 File: Revised Earthwork.docx


Item (Cubic Meters) Main Building Roadway Training Center Utility Plant Prison Camp TotalSpoil Excavation 1,266,966 95,830 356,105 140,405 277,365 2,136,671Rock Excavation 5,005,811 19,850 587,430 185,610 407,550 6,206,251Structural Fill 883,064 14,920 249,150 30,890 134,025 1,312,049Spoil Fill 8,096,932 40,050 414,805 704,615 0 9,256,402Base Elevation 495 Varies 480 480 550

Cardno Government Services DivisionPayne Gap/Lawson Site

Table PG-1A

Volumes by Facility

CARD003 Roxana-PayneGap - Attachment (2) 10-24-14, PG-1A, 10/24/2014 1 of 1

Item (Cubic Meters) Main Building Roadway Training Center Utility Plant Prison Camp TotalSpoil Excavation 4,881,322 0 0 1,507,283 648,618 7,037,223Rock Excavation 0 169,438 0 0 559,371 728,809Structural Fill 3,322,628 3,742 3,862,420 0 0 7,188,790Base Elevation 445 Varies 445 451 425

Cardno Government Services DivisionRoxana/Meade Farm Site

Table RX-1A

Volumes by Facility

CARD003 Roxana-PayneGap - Attachment (2) 10-24-14, RX-1A, 10/24/2014 1 of 1

TRAINING CENTER AREA

UTILITY PLANT AREA

PRISON CAMP AREA

ADDITIONAL PARKING AREA

MAIN BUILDING AREA

PROPOSEDFIRING RANGE

FUTURE STAFFTRAINING CENTERWITH PARKING

PROPOSED GARAGE /LANDSCAPE BUILDING

PROPOSEDUNITED STATESPENITENTIARY

PROPOSED FEDERAL PRISON CAMP

PROPOSED WASTEWATER SCREENING BUILDING

91 METER BUFFER ZONE

PROPOSED WAREHOUSE

PROPOSED UTILITY PLANTWITH RADIO TOWER

Site Grading - Payne Gap Study Area

Notes

Jewell

Lilly Cornett Branch

Big

Bran

chTo

lson

Cr

RT 160

Big

Bra nch

To lso nC

r

RT160

RT 160

Main State

RT 588

Route

2036

RT

588

RX-01

RX-06

RX-05

RX-07

RX-08RX-04

RX-11

RX-09

RX-10

RX-03

MAIN BUILDING AREA

PRISON CAMP AREA

UTILITY PLANT AREA

Roxana Study Area

Notes

PROPOSEDUNITED STATESPENITENTIARY

PROPOSED FEDERALPRISON CAMP

PROPOSED PARKING

91 METER BUFFER ZONE

PROPOSED GARAGE /LANDSCAPE BUILDING

PROPOSEDFIRING RANGE

FUTURE STAFF TRAININGCENTER WITH PARKING

PROPOSED WASTEWATER SCREENINGBUILDING

PROPOSED UTILITY PLANTWITH RADIO TOWER

PROPOSED OUTSIDEWAREHOUSE


Appendix C C-1 July 2015

APPENDIX C AIR EMISSION CALCULATIONS


C-2 Appendix C July 2015


TAB A. SUMMARY

Alternative 1 Payne Gap/Larson Site

VOC CO NOx SO2 PM10 PM2.5 CO2

Activity Year Tons Tons Tons Tons Tons Tons Metric TonsConstruction 1 7.51 31.38 104.89 1.83 217.39 26.86 10,913Construction 2 7.51 31.38 104.89 1.83 146.89 19.81 10,913Operations Yearly 0.70 29.33 21.36 0.18 1.16 0.58 1,271

Alternative 1 Roxana Site


Activity Year Tons Tons Tons Tons Tons Tons Metric TonsConstruction 1 2.99 12.90 38.68 0.76 158.52 17.87 4,006Construction 2 2.99 12.90 38.68 0.76 106.45 12.66 4,006Operations Yearly 0.70 29.33 21.36 0.18 1.16 0.58 1,271

TAB B. CONSTRUCTION EMISSIONS

Alternative 1 - Payne Gap/Larson

Table 1.1 Clearing218 acres


g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hrDozer 2,529 145 0.58 0.38 1.41 4.17 0.12 0.30 0.29 536Loader/Backhoe 2,529 87 0.21 1.43 7.35 6.35 0.15 1.06 1.03 692Small Backhoe 2,529 55 0.21 1.43 7.35 6.35 0.15 1.06 1.03 692


lb lb lb lb lb lb lbDozer 176.60 663.13 1,956.81 54.03 138.78 134.61 251,166

Loader w/ integral Backhoe 145.84 748.63 646.67 15.15 108.29 105.04 70,450Small backhoe 92.20 473.27 408.81 9.58 68.46 66.41 44,538


lb/mile lb/mile lb/mile lb/mile lb/mile lb/mile lb/mileDump Truck 1,158 230 16 0.0015 0.0080 0.0361 0.0000 0.0015 0.0015 3.4385

VOC CO NOx SO2 PM PM2.5 CO2

lb lb lb lb lb lb lbDump Truck 28.56 150.98 677.18 0.34 28.24 27.37 64,555

Subtotal in lbs 443 2036 3689 79 344 333 430709

Clearing Grand Total in Tons 0.22 1.02 1.84 0.04 0.17 0.17

Clearing Grand Total in Metric Tons 195.4

Table 1.2 Site PrepSite Prep - Excavate/Fill (CY) 25,760,829 CY

Grading (SY) 1,055,120 SY Assume compact 0.5 feet (0.166 yards) = 175,150 CY


g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hrExcavator 85,869 243 0.59 0.34 1.21 4.03 0.12 0.22 0.22 536Skid Steer Loader 103,043 160 0.23 0.38 1.47 4.34 0.12 0.31 0.30 536Dozer (Rubber Tired) 93,336 145 0.59 0.38 1.41 4.17 0.12 0.30 0.29 536Compactor 1,297 103 0.58 0.40 1.57 4.57 0.12 0.32 0.31 536Grader 375 285 0.58 0.34 1.21 4.07 0.12 0.23 0.22 536


lb lb lb lb lb lb lbExcavator 9,334.40 32,820.31 109,366.82 3,128.13 6,047.26 5,865.84 14,542,105

Skid Steer Loader 3,203.99 12,288.30 36,268.76 963.29 2,553.02 2,476.43 4,478,179Dozer (Rubber Tired) 6,630.48 24,897.59 73,469.64 2,028.50 5,210.52 5,054.20 9,430,197

Compactor 67.51 268.33 780.18 19.69 54.53 52.89 91,526Grader 46.94 164.93 555.75 15.74 30.80 29.87 73,160


MPH lb/mile lb/mile lb/mile lb/mile lb/mile lb/mile lb/mile

Dump Truck (14 CY) 85,869 5 230 0.0015 0.0080 0.0361 0.0000 0.0015 0.0015 3.4385


lb lb lb lb lb lb lbDump Truck (12 CY) 4,990.66 26,381.47 118,326.87 59.19 4,935.37 4,782.13 11,280,045

Subtotal in lb: 24,274 96,821 338,768 6,215 18,832 18,261 39,895,212

Site Prep Grand Total in Tons 12.14 48.41 169.38 3.11 9.42 9.13

Site Prep Grand Total in Metric Tons 18,096

Table 1.3 Gravel Work 8,844 CY


g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hrDozer 88 185 0.59 0.34 1.21 4.08 0.12 0.23 0.22 536Wheel Loader for Spreading 111 87 0.59 0.35 1.25 4.23 0.12 0.24 0.23 536Compactor 244 103 0.43 0.36 1.34 4.45 0.12 0.26 0.25 536


lb lb lb lb lb lb lbDozer 7.32 25.69 86.83 2.45 4.81 4.67 11,403

Wheel Loader for Spreading 4.36 15.62 52.96 1.44 2.99 2.90 6,703Compactor 8.56 31.88 106.02 2.74 6.12 5.94 12,759


lb/mile lb/mile lb/mile lb/mile lb/mile lb/mile lb/mileDump Truck 17,688 230 0.0015 0.0080 0.0361 0.0000 0.0015 0.0015 3.4385



Off-road Equipment

Hours of

Operation Engine HP Load Factor

On-road Equipment

Hours of

Operation Engine HP Speed (mph)

On-road Equipment Miles Engine HP

Off-road Equipment Hours Engine HP Load Factor



Subtotal (lbs): 47 215 884 7 41 39 91,686

Gravel Work Grand Total in Tons 0.02 0.11 0.44 0.00 0.02 0.02

Gravel Work Grand Total in Metric Tons 42

Table 1.4 Concrete WorkFoundation Work 6,676 CY

Sidewalks, etc. 445 CYTotal 7,120 CY Note: Assume all excavated soil is accounted for in Excavate/Fill and Trenching


g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hrConcrete Mixer 375 3.5 0.43 0.69 3.04 6.17 0.13 0.54 0.52 588Concrete Truck 339 300 0.43 0.38 1.75 6.18 0.11 0.27 0.26 530


lb lb lb lb lb lb lbConcrete Mixer 0.86 3.79 7.68 0.16 0.67 0.65 732Concrete Truck 36.60 168.36 596.22 10.99 25.91 25.14 51,102

Subtotal (lbs): 37 172 604 11 27 26 51,834

Concrete Work Grand Total in Tons 0.02 0.09 0.30 0.01 0.01 0.01

Concrete Work Grand Total in Metric Tons 24

Table 1.5 Building Construction360,497 SF Foundation802,922 SF Total


g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hrCrane 4,015 330 0.58 0.25 1.22 5.26 0.11 0.21 0.20 530Concrete Truck 4,015 300 0.43 0.19 1.45 4.32 0.12 0.21 0.20 536Diesel Generator 3,212 40 0.43 0.26 1.41 3.51 0.11 0.23 0.22 536Telehandler 8,029 99 0.59 0.51 3.94 4.93 0.13 0.52 0.51 595Scissors Lift 6,423 83 0.59 0.51 3.94 4.93 0.13 0.52 0.51 595Skid Steer Loader 4,015 67 0.59 1.69 7.97 6.70 0.15 1.19 1.15 691Pile Driver 9,295 260 0.43 0.46 1.55 5.90 0.11 0.31 0.30 530All Terrain Forklift 161 84 0.59 0.51 3.94 4.93 0.13 0.52 0.51 595


lb lb lb lb lb lb lbCrane 416.23 2065.88 8910.25 193.24 351.89 341.33 898,343

Concrete Truck 214.20 1660.73 4933.15 131.71 239.84 232.65 612,276Diesel Generator 31.97 171.58 427.25 13.14 28.24 27.39 65,301

Telehandler 526.84 4073.46 5096.29 132.25 538.81 522.64 614,797Scissors Lift 353.35 2732.10 3418.12 88.70 361.38 350.54 412,349

Skid Steer Loader 592.11 2787.66 2343.40 51.99 416.05 403.57 241,715Pile Driver 1063.00 3555.00 13520.50 260.50 719.00 697.00 1,213,343

All Terrain Forklift 8.94 69.13 86.48 2.24 9.14 8.87 10,433


lb/mile lb/mile lb/mile lb/mile lb/mile lb/mile lb/mileDelivery Truck 19,270 265 45 0.0015 0.0080 0.0361 0.0000 0.0015 0.0015 3.4385


lb lb lb lb lb lb lbDelivery Truck 1319.21 6973.59 31278.14 15.65 1304.60 1264.09 2,981,731

Subtotal (lbs): 4,526 24,089 70,014 889 3,969 3,848 7,050,288

Building Construction Grand Total in Tons 2.26 12.04 35.01 0.44 1.98 1.92

Building Construction Grand Total in Metric Tons 3,198

Table 1.6 PavingPavement - Surface Area 234,173 SF 4,337 CY

Paving - HMA 117,087 CF


g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hrGrader 717 145 0.59 0.38 1.41 4.16 0.12 0.30 0.29 536Roller 1,076 401 0.59 0.34 2.46 5.53 0.12 0.34 0.33 536Paving Machine 1,434 164 0.59 0.38 1.44 4.25 0.12 0.30 0.29 536Asphalt Curbing Machine 143 130 0.59 0.40 1.57 4.57 0.12 0.32 0.31 536


lb lb lb lb lb lb lbGrader 50.91 191.01 562.86 15.59 40.00 38.80 72,458Roller 191.53 1,381.86 3,105.60 64.67 190.04 184.34 300,633

Annual Emissions

Off-road Equipment

Hours of


Emission Factors

Off-road Equipment

Hours of


Emission Factors

Annual Emissions

On-road Equipment

Hours of


Off-road Equipment

Hours of


Paving Machine 116.27 441.36 1,301.01 35.26 91.79 89.04 163,901Asphalt Curbing Machine 9.58 38.09 110.74 2.79 7.74 7.51 12,991


lb/mile lb/mile lb/mile lb/mile lb/mile lb/mile lb/mileDump Truck 865 230 0 0.001521 0.008042 0.036070 1.80E-05 0.001504 0.001458 3.438541Water Truck 23 230 10 0.001521 0.008042 0.036070 1.80E-05 0.001504 0.001458 3.438541


lb lb lb lb lb lb lbDump Truck 21.99 116.26 521.44 0.26 21.75 21.07 49,709Water Truck 0.35 1.85 8.28 0.00 0.35 0.33 789

Weight of

HMA (tons) VOC VOC CO NOx SO2 PM10 PM2.5 CO2

lb/ton lb lb lb lb lb lb lbStandard Hot Mix Asphalt 117,087 8,489 0.04 339.55 - - - - - -

Subtotal (lbs): 730 2,170 5,610 119 352 341 600,480

Paving Grand Total in Tons 0.37 1.09 2.80 0.06 0.18 0.17

Paving Grand Total in Metric Tons 272

Table 1.7. Fugitive Dust Emissions

PM 10 days of PM2.5/

Year

tons/acre/

mo acres disturbance PM10 Total PM10 Ratio PM2.5 Total

Year 1 0.42 65.40 154 211.5 0.1 21.2Year 2 0.42 43.60 154 141.0 0.1 14.1

Table 1.8 Total Emissions


Year Tons Tons Tons Tons Tons Tons Metric TonsYear 1 7.51 31.38 104.89 1.83 217.39 26.86 10,913Year 2 7.51 31.38 104.89 1.83 146.89 19.81 10,913

Alternative 2 - Roxana

Table 2.1 Clearing161 acres


g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hrDozer 1,868 145 0.58 0.38 1.41 4.17 0.12 0.30 0.29 536Loader/Backhoe 1,868 87 0.21 1.43 7.35 6.35 0.15 1.06 1.03 692Small Backhoe 1,868 55 0.21 1.43 7.35 6.35 0.15 1.06 1.03 692


lb lb lb lb lb lb lbDozer 130.42 489.74 1,445.16 39.90 102.49 99.42 185,494

Loader w/ integral Backhoe 107.70 552.88 477.59 11.19 79.98 77.58 52,030Small backhoe 68.09 349.52 301.92 7.07 50.56 49.04 32,892


lb/mile lb/mile lb/mile lb/mile lb/mile lb/mile lb/mileDump Truck 855 230 16 0.0015 0.0080 0.0361 0.0000 0.0015 0.0015 3.4385



Subtotal in lbs 327 1504 2725 58 254 246 318092

Clearing Grand Total in Tons 0.16 0.75 1.36 0.03 0.13 0.12

Clearing Grand Total in Metric Tons 144.3

Table 2.2 Site PrepSite Prep - Excavate/Fill (CY) 8,124,680 CY

Grading (SY) 779,240 SY Assume compact 0.5 feet (0.166 yards) = 787,517 CY


g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hrExcavator 27,082 243 0.59 0.34 1.21 4.03 0.12 0.22 0.22 536Skid Steer Loader 32,499 160 0.23 0.38 1.47 4.34 0.12 0.31 0.30 536Dozer (Rubber Tired) 29,437 145 0.59 0.38 1.41 4.17 0.12 0.30 0.29 536Compactor 958 103 0.58 0.40 1.57 4.57 0.12 0.32 0.31 536Grader 277 285 0.58 0.34 1.21 4.07 0.12 0.23 0.22 536


On-road Equipment

Hours of

Operation Engine HP

Productivity

based Speed

Hot Mix Asphalt (HMA)

Volume of

HMA

(ft3)

Off-road Equipment

Hours of


On-road Equipment

Hours of



lb lb lb lb lb lb lbExcavator 2,943.97 10,351.16 34,493.08 986.58 1,907.24 1,850.02 4,586,419

Skid Steer Loader 1,010.50 3,875.59 11,438.76 303.81 805.19 781.04 1,412,368Dozer (Rubber Tired) 2,091.18 7,852.42 23,171.51 639.77 1,643.34 1,594.04 2,974,180

Compactor 49.86 198.17 576.19 14.54 40.27 39.06 67,595Grader 34.67 121.81 410.44 11.62 22.75 22.06 54,031


MPH lb/mile lb/mile lb/mile lb/mile lb/mile lb/mile lb/mile

Dump Truck (14 CY) 27,082 5 230 0.0015 0.0080 0.0361 0.0000 0.0015 0.0015 3.4385


lb lb lb lb lb lb lbDump Truck (12 CY) 206.00 1,088.97 4,884.29 2.44 203.72 197.40 465,617

Subtotal in lb: 6,336 23,488 74,974 1,959 4,623 4,484 9,560,210

Site Prep Grand Total in Tons 3.17 11.74 37.49 0.98 2.31 2.24

Site Prep Grand Total in Metric Tons 4,336

Table 2.3 Gravel Work 8,571 CY


g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hrDozer 86 185 0.59 0.34 1.21 4.08 0.12 0.23 0.22 536Wheel Loader for Spreading 107 87 0.59 0.35 1.25 4.23 0.12 0.24 0.23 536Compactor 236 103 0.43 0.36 1.34 4.45 0.12 0.26 0.25 536


lb lb lb lb lb lb lbDozer 7.09 24.90 84.15 2.38 4.66 4.52 11,051

Wheel Loader for Spreading 4.23 15.13 51.33 1.40 2.89 2.81 6,496Compactor 8.30 30.90 102.75 2.66 5.93 5.76 12,366


lb/mile lb/mile lb/mile lb/mile lb/mile lb/mile lb/mileDump Truck 17,142 230 0.0015 0.0080 0.0361 0.0000 0.0015 0.0015 3.4385



Subtotal (lbs): 46 209 857 7 39 38 88,855

Gravel Work Grand Total in Tons 0.02 0.10 0.43 0.00 0.02 0.02

Gravel Work Grand Total in Metric Tons 40

Table 2.4 Concrete WorkFoundation Work 6,676 CY

Sidewalks, etc. 445 CYTotal 7,120 CY Note: Assume all excavated soil is accounted for in Excavate/Fill and Trenching


g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hrConcrete Mixer 375 3.5 0.43 0.69 3.04 6.17 0.13 0.54 0.52 588Concrete Truck 339 300 0.43 0.38 1.75 6.18 0.11 0.27 0.26 530


lb lb lb lb lb lb lbConcrete Mixer 0.86 3.79 7.68 0.16 0.67 0.65 732Concrete Truck 36.60 168.36 596.22 10.99 25.91 25.14 51,102

Subtotal (lbs): 37 172 604 11 27 26 51,834

Concrete Work Grand Total in Tons 0.02 0.09 0.30 0.01 0.01 0.01

Concrete Work Grand Total in Metric Tons 24

Table 2.5 Building Construction360,497 SF Foundation802,922 SF Total


g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hrCrane 4,015 330 0.58 0.25 1.22 5.26 0.11 0.21 0.20 530Concrete Truck 4,015 300 0.43 0.19 1.45 4.32 0.12 0.21 0.20 536Diesel Generator 3,212 40 0.43 0.26 1.41 3.51 0.11 0.23 0.22 536Telehandler 8,029 99 0.59 0.51 3.94 4.93 0.13 0.52 0.51 595Scissors Lift 6,423 83 0.59 0.51 3.94 4.93 0.13 0.52 0.51 595Skid Steer Loader 4,015 67 0.59 1.69 7.97 6.70 0.15 1.19 1.15 691Pile Driver 9,295 260 0.43 0.46 1.55 5.90 0.11 0.31 0.30 530All Terrain Forklift 161 84 0.59 0.51 3.94 4.93 0.13 0.52 0.51 595

On-road Equipment Hours Engine HP



Off-road Equipment

Hours of


Emission Factors

Annual Emissions

Off-road Equipment

Hours of


Emission Factors


lb lb lb lb lb lb lbCrane 416.23 2065.88 8910.25 193.24 351.89 341.33 898,343

Concrete Truck 214.20 1660.73 4933.15 131.71 239.84 232.65 612,276Diesel Generator 31.97 171.58 427.25 13.14 28.24 27.39 65,301

Telehandler 526.84 4073.46 5096.29 132.25 538.81 522.64 614,797Scissors Lift 353.35 2732.10 3418.12 88.70 361.38 350.54 412,349

Skid Steer Loader 592.11 2787.66 2343.40 51.99 416.05 403.57 241,715Pile Driver 1063.00 3555.00 13520.50 260.50 719.00 697.00 1,213,343

All Terrain Forklift 8.94 69.13 86.48 2.24 9.14 8.87 10,433


lb/mile lb/mile lb/mile lb/mile lb/mile lb/mile lb/mileDelivery Truck 19,270 265 45 0.0015 0.0080 0.0361 0.0000 0.0015 0.0015 3.4385


lb lb lb lb lb lb lbDelivery Truck 1319.21 6973.59 31278.14 15.65 1304.60 1264.09 2,981,731

Subtotal (lbs): 4,526 24,089 70,014 889 3,969 3,848 7,050,288

Building Construction Grand Total in Tons 2.26 12.04 35.01 0.44 1.98 1.92

Building Construction Grand Total in Metric Tons 3,198

Table 2.6 PavingPavement - Surface Area 204,645 SF 3,790 CY

Paving - HMA 102,323 CF


g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hr g/hp-hrGrader 627 145 0.59 0.38 1.41 4.16 0.12 0.30 0.29 536Roller 940 401 0.59 0.34 2.46 5.53 0.12 0.34 0.33 536Paving Machine 1,253 164 0.59 0.38 1.44 4.25 0.12 0.30 0.29 536Asphalt Curbing Machine 125 130 0.59 0.40 1.57 4.57 0.12 0.32 0.31 536


lb lb lb lb lb lb lbGrader 50.91 191.01 562.86 15.59 40.00 38.80 72,458Roller 191.53 1,381.86 3,105.60 64.67 190.04 184.34 300,633

Paving Machine 116.27 441.36 1,301.01 35.26 91.79 89.04 163,901Asphalt Curbing Machine 9.58 38.09 110.74 2.79 7.74 7.51 12,991


lb/mile lb/mile lb/mile lb/mile lb/mile lb/mile lb/mileDump Truck 756 230 17 0.001521 0.008042 0.036070 1.80E-05 0.001504 0.001458 3.438541Water Truck 20 230 10 0.001521 0.008042 0.036070 1.80E-05 0.001504 0.001458 3.438541


lb lb lb lb lb lb lbDump Truck 19.22 101.60 455.69 0.23 19.01 18.42 43,441Water Truck 0.31 1.61 7.23 0.00 0.30 0.29 690

Weight of

HMA (tons) VOC VOC CO NOx SO2 PM10 PM2.5 CO2

lb/ton lb lb lb lb lb lb lbStandard Hot Mix Asphalt 102,323 7,418 0.04 296.74 - - - - - -

Subtotal (lbs): 685 2,156 5,543 119 349 338 594,113

Paving Grand Total in Tons 0.34 1.08 2.77 0.06 0.17 0.17

Paving Grand Total in Metric Tons 269.48

Table 2.7. Fugitive Dust Emissions

PM 10 days of PM2.5/

Year

tons/acre/

mo acres disturbance PM10 Total PM10 Ratio PM2.5 Total

Year 1 0.42 48.30 154 156.2 0.1 15.6Year 2 0.42 32.20 154 104.1 0.1 10.4

Table 2.8 Total Emissions


Year Tons Tons Tons Tons Tons Tons Metric TonsYear 1 2.99 12.90 38.68 0.76 158.52 17.87 4,006Year 2 2.99 12.90 38.68 0.76 106.45 12.66 4,006

Annual Emissions

On-road Equipment

Hours of


Load Factor

On-road Equipment

Hours of

Operation Engine HP

Productivity

based Speed

Hot Mix Asphalt (HMA)

Volume of

HMA

(ft3)

Off-road Equipment

Hours of

Operation Engine HP

TAB C. OPERATIONAL EMISSIONS

Factory-fabricated and assembled water-tube flexible tube boilers, dual fired natural gas and fuel oil.

Two diesel Emergency Generators -2 megawatts each or 2682 HP each

Table 1. Operational Emissions - Emergency Generators

Assume the IC engines are typically operated 0.5 hours per week for testing and maintenance = 26 hr/yr

Assume additional five 24-hour periods for total power outages per year = 120 hr/yr Pollutant Emission Factors

146 Total Hours Diesel Fuel a, b

> 447 kW

VOC CO NOx SO2 PM CO2 lb/hp-hr

kW # lb/yr lb/yr lb/yr lb/yr lb/yr lb/yr CO 0.0055

2000 2 503 4,307 10,181 10 548 908,447 NOx 0.013

Tons/yr 0.25 2.15 5.09 0.00 0.27 454 PM 0.0007

metric tons/yr 412 SO2c 0.00809 S

S 0.0015

VOCd

0.000642

CO2 1.16

b Emission factors from U.S. EPA. Compilation of Air Pollutant

Emission Factors - Volume I (AP-42), Section 3.4, 5th Edition; .

factors based upon power outputc The variable S in the emissions factor equals the sulfur

content of the fuel expressed as percent weight.dVOC = TOC - methane (9%)

SO2 factor was assumed to equal 0.0015 for diesel fuel.

Table 2. Operational Parameters - Boilers

1-02-005-02/03, 1-03-005-02/03 Distillate oil fired Boilers <100 Million Btu/hr

Example boiler that is < 100 MM Btu:

Pollutant (lb/103 gal)a,b

Heat Input

(MMBtu/hr)a Fuel Type

Annual

Hours of

Operation

Est. Qty Oil

consumed

Annually

(gal) CO 5

15 Oil 5100 759,900 NOx 20

15 Oil 5100 759,900 PM10 1

PM2.5 0.25

Total est. quantity of oil consumed annually 1,519,800 gal SO2 0.213 0.0015 Percent Sulfur content in fuel

VOC 0.34

140,000 btu/gal fuel oil 149 gal/hour fuel consumption @ CO2 22,300

80 % efficiency N2O 0.26

Assume heat 10/15 to 4/14 CH4 0.216

Generator

Emission Factor

182 heating daysa Emission factors from U.S. Environmental Protection Agency. Compilation

183 non heating days of Air Pollutant Emission Factors - Volume I (AP-42), Section 1.3, 5th Edition.b Emission factors based on burning fuel oil with a heating value of 140 MMBtu/103 gal

Table 3. Annual Emissions for Boilers

VOC CO NOx SO2 PM10 PM2.5 CO2 N2O CH4

258 3800 15198 162 760 190 3800 198 164

258 3800 15198 162 760 190 3800 198 164

Total in Tons/yr 0.26 3.80 15.20 0.16 0.76 0.19 3.80 0.20 0.16

CO2e = 62 metric tons/yr

Table 4. Total Annual Emissions for All Equipment

Stationary Source VOC t/yr CO t/yr NOx t/yr SO2 t/yr PM10 t/yr PM2.5 t/yr CO2e MT/yr

Generators 0.25 2.15 5.09 0.00 0.27 0.27 412

Boilers 0.26 3.80 15.20 0.16 0.76 0.19 62

Total 0.51 5.95 20.29 0.17 1.03 0.46 474

Table 5. Commuting Staff 300 per day

3VOCs 3CO 3NOx 3SO23PM10

3PM2.54,5CO2

Vehicles # vehicles # days4mi/day lb/mi lb/mi lb/mi lb/mi lb/mi lb/mi g/mi

passenger vehicles 300 365 40 8.593E-05 1.067E-02 4.873E-04 7.357E-06 5.68927E-05 5.19227E-05 182.00

VOCs CO NOx SO2 PM10 PM2.5 CO2

lb lb lb lb lb lb g

376.36 46755.73 2134.28 32.23 249.19 227.42 797,160,000

Tons per Year 0.19 23.38 1.07 0.02 0.12 0.11

Metric Tons per Year 797

CO2e in metric tons/year 797

Table 6. Total Annual Operating Emissions from Stationary Sources and Commuters

VOC t/yr CO t/yr NOx t/yr SO2 t/yr PM10 t/yr PM2.5 t/yr CO2e MT/yr

Operating Emissions 0.70 29.33 21.36 0.18 1.16 0.58 1,271

Boiler 1

Boiler 2

Emission Source

Annual Emissions in lbs

TAB D. CONSTRUCTION ASSUMPTIONS

Buildings Common to both alternatives

Clearing (AC)

Grading

(SY)

Site Prep -

Excavate/Fill

(CY)

Building

Construction -

Total Size

(sm)

Building

Construction -

Total Size (sf)

Foundation

footprint (sm)

Foundation

footprint

(sf) # Stories Paving (CY)

Gravel

Work (CY)

Concrete

Work -

sidewalks,

etc (CY)

Concrete

Work -

foundation

(CY)

Central Utility Plant 1,217 13,100 1,217 13,100 1 243 16 243

Firing Range 96 1,033 96 1,033 1 19 1 19

Outside Warehouse 3,279 35,295 3,279 35,295 1 654 44 654

UNICOR Warehouse 1,375 14,800 1,375 14,800 1 274 18 274

Staff Training Bldg 910 9,795 910 9,795 1 181 12 181

Penitentiary 61,654 663,637 20,551 221,212 3 4,097 273 4,097

Prison Camp 6,063 65,262 6,063 65,262 1 1,209 80 1,209

4,337 2,168

Fill/Excavate - Payne Gap 25,760,829

Grading - Payne Gap 1,055,120

Clearing Payne Gap 218

Payne Gap Total 218 1,055,120 25,760,829 74,594 802,922 33,491 360,497 4,337 8,844 445 6,676

3,790 1,895

Fill/Excavate - Roxana 8,124,680

Grading - Roxana 779,240

Clearing Roxana 161

Roxana Total 161 779,240 8,124,680 74,594 33,491 3,790 8,571 445 6,676

300 full-time staff

Alternative 1. Payne Gap/Larson

753 acres

218 acres cleared

2,794,660 CY soil excavation 10,912,130 CY total excavation Total excavation + fill= 25,760,829

8,117,470 CY rock excavation

1,540,797 CY structural fill 14,848,699 CY total fill

13,307,902 CY spoil fill

Road Estimates Assume road width of 18 feet

Entry road/to warehouses 900 m 2,953 ft

Project Name

Roads/Parking - Payne Gap

Roads/Parking - Roxana

USP access 600 m 1,969 ft

Camp access 2000 m 6,562 ft

11,483 ft total

206,693 SF total

Parking/paved areas Require parking for 100 vehicles per shift; overlap; visitors; deliveries

27,480 sf total

Alternative 2 Roxana

700 acres

161 acres cleared

2,928,922 CY soil excavated 3,831,679 CY total excavation Total excavation + fill= 8,124,680

902,757 CY rock excavated

2,087,607 CY structural fill 4,293,001 CY total fill

2,205,394 CY spoil fill

25 ac dynamic compaction

Road Estimates Assume road width of 18 feet

Total length 3000 m

9,843 ft total

177,165 SF total

Parking/paved areas Require parking for 100 vehicles per shift; overlap; visitors; deliveries

27,480 sf total


Appendix D D-1 July 2015

APPENDIX D ENHANCED UTILITY REPORT


D-2 Appendix D July 2015


Enhanced Utility Investigation Report


Letcher County, Kentucky

Prepared by:

October 2014United States Department of Justice


320 First St NW

Washington, DC 20534

THIS PAGE INTENTIONALLY LEFT BLANK

BOP – Letcher County **DRAFT** Enhanced Utility Investigation Report

ES-1

EXECUTIVE SUMMARY

In 2011, Cardno (formerly TEC Inc.) was retained by the Federal Bureau of Prisons (BOP) to conduct a Feasibility Study for the development of a 1,800-bed federal correctional facility to be located at one of three identified sites located near the town of Whitesburg in Letcher County, Kentucky (KY). As part of the Feasibility Study, a Utility Investigation Report was prepared in order to assess the viability and costs associated with providing utilities to each site. The purpose of the utility report was to assess the availability of water, sanitary sewer, natural gas, electricity, and telecommunications for each of the proposed locations.

The results of the Feasibility Study have allowed the project to proceed into the next phase, which includes the preparation of an Environmental Impact Statement (EIS). At the conclusion of the Feasibility Study, it was determined that one of the three potential sites is not a viable option for constructing a new BOP correctional facility and therefore the EIS includes the assessment of only two sites. Also, since the conclusion of the Feasibility Study, the size of the facility has been reduced to a 1,200-bed correctional facility. To address this change and account for any other possible changes to the utilities over the past three years, the EIS includes the preparation of this Enhanced Utility Investigation Report. This “enhanced” report replaces the initial Utility Study. All information presented in the original report has been updated to reflect the changes associated with the various utility systems. All pertinent utility information is incorporated into this Enhanced Utility Investigation Report.

It is assumed that the on-site utility requirements would be comparable for both sites and that the factors determining the most viable and cost effective option would be related to connecting each of the potential sites to the existing utility infrastructure. Therefore, on-site utilities have not been included in this assessment. The two sites included in this report are Roxana/Meade Farm and Payne Gap, both of which are located within 10 miles of the town of Whitesburg. To determine viability of bringing the utilities to both identified sites, the capacity of the existing utility systems and the distance from the proposed connection points were assessed and cost estimates were prepared.

For both sites, water service has been extended or is in the process of being extended to the property lines and the wastewater utility providers have indicated that they intend to extend their existing systems to the proposed sites at no cost to BOP; however, it is likely that BOP will need to provide some cost sharing for the sanitary sewer extension to the Roxana site, if it is selected. Conversations with American Electric Power (AEP), the power provider for both sites, indicate that the existing system has ample capacity to handle the facility at either of the potential locations and there would be no costs to BOP associated with the AEP connection, assuming overhead connections. The telecommunications lines also have adequate capacity to provide service to both sites, but BOP will be responsible for the cost of the necessary infrastructure to connect to the existing telecommunications systems. For the natural gas connection, both sites would require the installation of a meter and tap, which would be the responsibility of BOP. This cost would be comparable at both sites. At the Roxana/Meade Farm site there are multiple gas wells that would need to be closed and abandoned and lines that need to be relocated. This would require a BOP investment of approximately $12.8 million. Similarly there is a well at the Payne Gap site that would need to be abandoned and a 16-inch natural gas line that would need to be relocated around the perimeter of the site. These costs are estimated at $5 million.

With respect to capital investment for all utilities, the Roxana site is more costly by nearly $7 million. However, the time associated with abandoning the wells is about six months, compared to a minimum of


ES-2

two years to relocate the 16-inch gas line at Payne Gap. These cost and schedule factors associated with the natural gas components are critical to the site selection recommendation as it pertains to the utilities. All other utility costs and scheduling factors are relatively comparable and have negligible impacts on site selection.

In addition to identifying the most viable location for the construction of a new BOP federal correctional facility, this study identifies some potential options for implementing alternative energy and sustainability practices at the new facility. Kentucky does not lie within a prime area of the country that supports the implementation of a primary wind, solar, or geothermal alternative energy system. However, solar and geothermal systems could be further evaluated for supplementing the power systems at the new facility. This evaluation would be needed after site selection is complete and detailed design planning commences. Additionally, the implementation of practices such as gray water disposal, water reduction efforts, and installation of green roof technology should also be considered during design to help meet sustainability goals.


i

TABLE OF CONTENTS

1.0 INTRODUCTION .............................................................................................................................................................. 1

2.0 BACKGROUND INFORMATION .................................................................................................................................. 2

3.0 DESIGN CRITERIA .......................................................................................................................................................... 3 3.1 Utility Systems ................................................................................................................................................... 3

3.1.1 Water .......................................................................................................................................................................3

3.1.2 Sanitary Sewer .....................................................................................................................................................4

3.1.3 Natural Gas ............................................................................................................................................................4

3.1.4 Electric ....................................................................................................................................................................4

3.1.5 Telecommunications .........................................................................................................................................4

4.0 UTILITY PROVIDERS..................................................................................................................................................... 5 4.1 Roxana/Meade Farm ....................................................................................................................................... 6 4.2 Payne Gap ......................................................................................................................................................... 10

5.0 ALTERNATIVE ENERGY AND SUSTAINABILITY ............................................................................................... 14 5.1 Alternative Energy ........................................................................................................................................ 14

5.1.1 Wind Energy ...................................................................................................................................................... 15

5.1.2 Photovoltaics ..................................................................................................................................................... 16

5.1.3 Geothermal Systems ...................................................................................................................................... 17

5.1.4 Biomass Energy ................................................................................................................................................ 18

5.2 Sustainability ....................................................................................................................................................... 19

6.0 CONCLUSIONS .............................................................................................................................................................. 20

APPENDICES

Appendix 1 – Field Photographs............................................................................................................................................................. 21

Appendix 2 – Site Investigation Utility Meetings Memo .............................................................................................................. 31


ii

LIST OF FIGURES

Figure 1-1 - Potential BOP Federal Correctional Facility Locations ......................................................................................... 1

Figure 4-1 - Existing Utilities at Roxana/Meade Farm Site .......................................................................................................... 9

Figure 4-2 - Existing Utilities at Payne Gap Site .............................................................................................................................. 13

Figure 5-1 - Kentucky Wind Map ........................................................................................................................................................... 15

Figure 5-2 - Photovoltaic Solar Resource of the U.S. ..................................................................................................................... 16

Figure 5-3 - Geothermal Resource of the U.S. ................................................................................................................................... 17

Figure 5-4 - Biomass Resources Available in the U.S. ................................................................................................................... 18

LIST OF TABLES

Table 4-1 – Utility Providers ...................................................................................................................................................................... 5

Table 4-2 – Roxana/Meade Farm Utility Service Opinion of Probable Cost ......................................................................... 7

Table 4-3 – Payne Gap Utility Service Opinion of Probable Cost ............................................................................................. 11

Table 6-1 – Utility Connection - Probable Cost Comparison ...................................................................................................... 20


1

1.0 INTRODUCTION Cardno has been retained by the Federal Bureau of Prisons (BOP) to prepare an Environmental Impact Statement (EIS) for the development of a 1,200-bed federal correctional facility in Letcher County, Kentucky (KY). Two potential sites located near the town of Whitesburg are currently being considered for the construction of the new facility, as illustrated in Figure 1-1.

The two potential sites are identified as Roxana/Meade Farm and Payne Gap. As depicted in Figure 1, the Roxana/Meade Farm site is located less than 10 miles to the west of Whitesburg and the Payne Gap site is located on the Kentucky-Virginia border, less than 10 miles to the east of Whitesburg. This report is being prepared in coordination with the EIS and is designed to investigate the availability, cost, and feasibility of providing utilities to both of the potential sites, identify the pros and cons for each of the sites, and develop recommendations for potential development.

Figure 1-1 - Potential BOP Federal Correctional Facility Locations


2

2.0 BACKGROUND INFORMATION This “Enhanced” Utility Investigation Report is an enhancement to the Utility Investigation Report prepared for BOP in 2011. In 2011, Cardno (formerly TEC Inc.) was retained by BOP to prepare the initial Utility Investigation Report, in which three sites were considered. In addition to the two sites that remain under consideration, the third site included the Van Fields Site, just north of Whitesburg, on Route 15.

Prior to the initial Utility Investigation Report, several studies had previously been performed in support of the potential construction of a new federal correctional facility at the three potential sites. These studies include:

• Site Reconnaissance Study prepared by the Louis Berger Group (November 2008) • Mine History Reports (each site) prepared by Summit Engineering (August 2010) • Site Investigation Trip Memo prepared by KCI Technologies (October 2010)

Information from each of these studies was utilized in developing background information, baseline data starting points, initial contact information, and additional evaluation criteria.

The Site Investigation Trip memo (KCI 2010) provided ranking criteria for the potential sites. Based on a scale of 1 to 5 (1 being the highest), the average utilities rank for the three sites ranged from 2.25 to 3.25, indicating the results of the initial utility assessment were fairly comparable for the three potential sites. However, based on other concerns associated with past mining, accessibility, and excavation requirements, KCI recommended that the Payne Gap site be removed from consideration. Since the purpose of this report is to further assess the utilities, the BOP decided to continue to include the Payne Gap site in this study, as it is still a feasible option.

Several other studies were performed concurrently with the initial Utility Investigation Report. One such study was a Topographical and Boundary survey performed by Marshall Miller and Associates (MMA). This survey has allowed realistic layouts of the facilities to be developed within the property boundaries. The layouts along with the elevations at the site will be imperative for infrastructure design, most importantly for establishing requirements for water distribution and sanitary sewer lift stations.


3

3.0 DESIGN CRITERIA This section describes the utility needs for the proposed BOP federal correctional facility and the utility design criteria to meet those needs. The initial basis for utility design criteria was outlined in the Site Reconnaissance Study prepared by the Louis Berger Group in November 2008. The criteria outlined in the Site Reconnaissance Study were based on a 1,400 bed facility. This was utilized as an initial starting point for discussions with the local utility providers to determine if the required minimum demand was available, and if not, what would be required to provide utilities to the potential sites. In addition to the minimum criteria, the potential for increased capacity due to future expansions and plans was investigated. The initial population of 1,400 beds for the proposed BOP facility, as discussed in the Site Reconnaissance Study, was initially increased to a 1,800 bed facility in the initial Utility Investigation Report, but has been decreased to a 1,200 bed facility in this final study.

3.1 Utility Systems The design criteria used to assess the utilities in this report are based on providing utilities to the US Penitentiary (USP) and Federal Prison Camp (FPC) facilities. The total capacity for these two facilities is 1,200 inmates and it is estimated that approximately 300 full-time staff would be required to operate the two facilities as well as the ancillary support facilities listed below. The utility usage estimated in this section is based on providing utilities to similar types and sizes of facilities.

USP and FPC Support Facilities • Central Utility Plant 1,217 square feet • Firing Range 96 square feet • Outside Warehouse 3,279 square feet • UNICOR Warehouse 1,375 square feet • Staff Training Building 910 square feet

3.1.1 Water

• Average Water Demand: USP and FPC Facilities: 215 gallons per day (gpd) per bed x 1,200 beds = 258,000 gpd Utility Plant: 2,000 gpd per acre x 0.03 acres = 60 gpd Warehouses: 1,000 gpd per acre x 0.1 acres = 100 gpd Training Building: 20 gpd per person x 300 people = 6,000 gpd

Total Average Water Demand = 264,160 gpd or approximately 185 gallons per minute (gpm)

• Peak Water Demand: 4 times average water demand 185 gpm x 4 = 740 gpm

• Fire Flow Requirement: 2,000 gpm for four hours • Minimum Water Pressure: 40 pounds per square inch (psi) • Preferred Water Pressure: 80 psi • Water Storage Capacity: 500,000 gallons

[The utility provider must be able to meet peak demands and fire flow requirements during select periods when the tank is taken off-line for maintenance and repairs]


4

3.1.2 Sanitary Sewer

• Average Wastewater Flow: 85% of Average Water Demand 264,160 gpd x 0.85 ~ 225,000 gpd 156 gpm

• Peak Wastewater Flow: 3.5 times average wastewater flow 156 gpm x 3.5 = 546 gpm

3.1.3 Natural Gas

• Usage based on typical correctional facility: Annual Energy Usage: 50 – 70 million cubic feet (mcf) Maximum Hourly Usage: 25,000 – 28,000 cubic feet per hour (cfph) Maximum Daily Usage: 250,000 – 280,000 cubic feet (cf)

3.1.4 Electric

• Usage based on typical correctional facility: System Requirements: 12–15 kilovolt (kV) system with 3-phases and 4-wire components Average Energy Usage: 18 – 19 million kilowatt hours (kWh) Demand Load: 4,500 – 5,000 kilowatts (kW) On-site Transformer Requirements: 5,000 kilovolt ampere (kVa)

3.1.5 Telecommunications Telecommunications service also includes internet and security connections for communications with outside correctional officials and facilities. The minimum requirements for new construction, generally coordinated through the local telecommunications company, include:

• Primary Rate Interface (PRI) T1 for the Federal Telecommunications System • Integrated Services Digital Network (ISDN) T1 for local calls • 200 pair copper • 400 continuous Direct Inward Dialing (D.I.D.) numbers


5

4.0 UTILITY PROVIDERS The information regarding utility providers for the five utility systems listed in Section 3.0 was gathered through phone conversations, email communications, and on-site meetings held with the individual utility providers for each of the sites during the preparation of the initial Utility Investigation Report.

The Letcher County Water and Sewer District (LWSD) provides sanitary sewer service to the Roxana/Meade Farm site through the Whitesburg Wastewater Treatment Plant (WWTP). The Whitesburg WWTP was recently upgraded in anticipation of the proposed BOP federal correctional facility to a capacity of 600,000 gpd with an average load of 300,000 gpd. The facility was built with the ability to phase-in upgrades as necessary to handle additional flows.

The LWSD is in the process of upgrading and connecting all of the county’s water systems in order to provide redundancy in the system. These plans have included connections between all the existing water systems, and new connections in the city of Jenkins and Fleming Neon. Water service has been or is in the process of being extended to both potential BOP sites.

American Electric Power (AEP) provides electricity in the vicinity of both sites. AEP recently constructed a 4 megawatt facility in the vicinity of the Roxana site for a gas co-generation plant. The plant was never constructed; therefore, there is ample capacity in the existing system to handle the additional load from a new BOP facility, regardless of site selection.

Telecommunication and natural gas lines are provided by various utility providers. The providers are listed in Table 4-1, and the systems adjacent to the Roxana/Meade Farm and Payne Gap sites are discussed further in Sections 4.1 and 4.2, respectively. In addition, a brief discussion is provided for each site, which includes estimates of probable connection costs, summaries of the advantages and disadvantages associated with utility connections to each site, a map of each site, and the locations of the existing utility infrastructure.

Table 4-1 – Utility Providers

Site

Utility Providers

Water Wastewater Natural Gas Electric Telecommunication

Roxana/Meade Farm LWSD LWSD

Equitable Gas (EQT) & Clean Gas

Inc./Hayden Harper AEP Birch

Communications

Payne Gap LWSD City of Jenkins EQT AEP Windstream


6

4.1 Roxana/Meade Farm The Roxana/Meade Farm property is located southwest of Whitesburg, with existing access from Route 160 east of the intersection with State Highway 588. As described in Summit Engineering’s (2010) Mine History Report, the property has past mountaintop mining with approximately 30 feet of spoils and has a level top. There are multiple gas lines and wells throughout the area of interest.

Water Service: Public water would be provided by the LWSD. LWSD is in the process of extending their water system to the eastern property boundary of the proposed Roxana site. Therefore, to bring water to the new BOP federal correctional facility, the connection would be limited to a tap on the existing system near the property boundary and the installation of on-site infrastructure. The new line being run to the site is an 8-inch pipeline and should be adequate to meet the 80 psi pressure requested for the BOP facilities. This water system is capable of providing 4 million gallons per day to the region, which is ample capacity to meet the needs of the new BOP facilities.

Sanitary Sewer Service: LWSD would also be providing sanitary sewer service to the proposed Roxana site. As with the water service, LWSD is also extending their wastewater collection service, but the extension has not yet been completed as far as the proposed Roxana site. Currently, the connection point is approximately 2.75 miles from the proposed site. To connect to the existing system, construction of a lift station would be required as well as the installation of approximately 2.75 miles of a new collection system. Although the initial intention of LWSD was to construct the required extension all the way to the proposed site at no cost to the BOP, LWSD would likely need some funding assistance to complete the extension of the collection system to the proposed site. This assistance may need to be provided by or be facilitated by BOP. For the purposes of this report, it is assumed that LWSD would require 50% contribution from BOP for this extension.

Natural Gas: The site consists of multiple gas wells and gas transmission lines. Currently there are 14 Hayden Harper gas wells and 1 EQT gas well within the Roxana/Meade Farm property. Since the BOP does not own or operate gas wells and does not become involved in mineral rights, all wells within the property boundary would need to be closed and abandoned, regardless of proximity to proposed facilities. It would take up to six months to close and abandon these wells. The cost associated with closure and abandonment of wells can range from $300,000 to $1,000,000. Due to the large production potential of many of the wells at this site, it is estimated that each closure would cost approximately $850,000. To abandon all 15 wells, the associated costs would be approximately $12.75 million. There would also be a connection fee for BOP to connect to the natural gas distribution system. Since the system is in close proximity to the site, the connection would be limited to the cost of the meter and tap, which is estimated at $110,000.

Electric Power: As indicated in Section 4.0, AEP has sufficient capacity in the immediate vicinity to supply power to the proposed BOP facility. With the projected load and revenue from the proposed BOP facility, AEP has indicated that the connection to the handoff point for the secure perimeter would be provided at no cost to the BOP. The service would be provided via overhead lines directly to the handoff point to the proposed BOP facility with no on-site facilities needed. If underground connections (conduit) are required for service to the proposed BOP facility, the cost of the conduit and running of lines would be the responsibility of the BOP and would be calculated as part of the site development costs.

Telecommunications: Birch Communications, the telecommunications company serving the area, has the capability to meet the minimum requirements of the proposed BOP facility. There is a remote


7

terminal located in close proximity. However approximately 2 miles of fiber optic cables and 4 miles of copper cables would be required to bring service to the edge of the property. At this time, it should be assumed that the costs to install these cables would be the responsibility of BOP. However, during the design phase, Birch Communications should be contacted to discuss potential cost-sharing options.

Opinion of Probable Costs: The costs to provide adequate utility service to the Roxana/Meade Farm site are presented in Table 4-2. The estimates are based on the information provided through the utility provider interviews and based on the engineering reports listed in Section 2. These costs are intended as an indicator of the general order of magnitude for the activities outlined. These costs should be used for site cost comparison purposes only. More detailed studies will be required to identify all factors associated with the actual costs required for extending the utility infrastructure and making the connections.

Table 4-2 – Roxana/Meade Farm Utility Service Opinion of Probable Cost

Utility Items Included

Cost

BOP Others1

Water Costs associated with bringing water to the site will be associated with installation of on-site infrastructure - TBD during design

$0 $0

Sanitary Sewer

- Gravity Main Force Main - Manholes - Lift Station(s) - 15% Construction Contingency - 30% Design/Admin/ROW/Legal/ Permitting

$1.4 million $1.4 million

LWSD to provide May require some assistance

from BOP (50% assumed)

Natural Gas Meter and Tap (incl. connection fees) $110,000

$0 Well Closure: $850,000 x 15 $12,750,000

Electrical N/A (assumes no underground conduit required) $0 $0

Telecommunications

- Construction of Local Remote Terminal - Installation of fiber optic cables - Installation of copper cable - Local electronics

$165,000 $0

UTILITY CONNECTION FEES $14,425,000 $1,400,000

TOTAL $15,825,000

1. Fee responsibility breakdown assumes the utility provider would contribute the portion of the costs listed above. If conditions change, BOP could potentially be responsible for all or portions of the “Others” fees.


8

Advantages:

• Proposed site is relatively level

• Water transmission main has already been brought to the site

• LWSD already has plans underway to extend the wastewater collection system to the site

• Sufficient capacity available to supply electric power to the site at no cost to BOP

Disadvantages:

• Multiple gas wells and lines on the property would need to be closed and abandoned and/or relocated off the site at the expense (costly) of BOP

• Extension of the wastewater collection system would likely require some funding assistance from BOP

• There is no telecommunication remote terminal in the vicinity of the proposed Roxana/Meade Farm site, requiring the construction of a new remote terminal

A map of the existing utilities in the vicinity of the Roxana/Meade Farm site is included in Figure 4-1.


9

Figure 4-1 - Existing Utilities at Roxana/Meade Farm Site


10

4.2 Payne Gap The Payne Gap property is located east of Whitesburg along the south side of Highway 119, between Routes 805 and 23. The property has deep mines and would need to be excavated and filled in order to create a level surface for construction. This location offers the most direct access to major highways.

The Site Investigation Trip memo (KCI 2010) recommended that the Payne Gap site be removed from consideration due to “significant concerns with its locations, past mining, and excavation.” However the BOP feels that the site should remain under consideration because of its accessibility and proximity to alternative utility suppliers not associated with the Roxana/Meade Farm site.

Water Service: Public water would be provided to the Payne Gap site by the LWSD. As described previously, LWSD has recently been extending its service area. In addition to extending the service to Roxana, the service has already been extended along Highway 119, adjacent to the proposed Payne Gap property. An 8-inch diameter watermain is in the vicinity of the Payne Gap site, and the water pressure near the connection point is approximately 110 psi. This is more than adequate to meet the 80 psi pressure requirements of the BOP facilities. Currently, the system in the vicinity of Payne Gap is being upgraded to ensure the average and peak water demands at the new facilities would be met. As with the Roxana site, the costs to BOP to provide water to its facilities would be limited to tapping the existing watermain and installing the necessary on-site water distribution infrastructure. All other water system upgrades are being provided by LWSD.

Sanitary Sewer Service: Sanitary sewer services would be provided by the City of Jenkins and handled at the Jenkins WWTP. The nearest connection point to the Payne Gap site is located in close proximity to the Gateway Industrial Park in Jenkins. The connection point is an 8-inch gravity line, which would provide sufficient capacity for the estimated flow from the proposed BOP federal correctional facility. In order to reach the proposed connection point, construction of a lift station would be required. According to City officials and their representative engineering firm, Nesbitt Engineering, the WWTP has sufficient capacity to handle the proposed volume from the proposed BOP Facility. The City of Jenkins intends to provide construction of the sanitary sewer services to the proposed BOP facility at no cost to the BOP.

Natural Gas: There is one gas well on-site, as well as a transmission line running directly through the property. The transmission line is a 16-inch high pressure main, owned and operated by EQT. The well is also owned and operated by EQT. The cost to relocate the gas line would be approximately $455 per linear foot (lf) and there would be a fee of approximately $110,000 for the connection and installation of a meter. Due to its proximity to the Jefferson National Forest, it would be necessary to reroute the new transmission line to the north and along Highway 119. This would require approximately 9,000 feet of a new pressure main. It is anticipated that it would take a minimum of two years to design, permit, and install this pressure main. In addition to the transmission line relocation, the EQT well would need to be abandoned and plugged. This would require an additional investment of approximately $850,000 from the BOP.

Electric Power: As indicated previously, AEP has sufficient capacity in the immediate vicinity to supply power to the proposed facility. With the projected load and revenue from the BOP facility, AEP has indicated that the connection to the handoff point for the secure perimeter would be provided at no cost to the BOP. The service would be provided via overhead lines directly to the handoff point to the secure facility with no on-site facilities needed. If underground connections (conduit) are required for service to


11

the proposed BOP facility, the cost of the conduit and running of lines would be the responsibility of the BOP and would be considered part of the site development costs.

Telecommunications: Windstream, the telecommunications company serving the area, has the capability to meet the minimum requirements of the proposed BOP facility. However, the connection to the existing infrastructure would be the responsibility of BOP. This would include the connection to the fiber cables at a splice location adjacent to the site and the connection to the copper cables at the Gateway Industrial Park in Jenkins.

Opinion of Probable Costs: The costs to provide adequate utility service to the Payne Gap site are presented in Table 4-3. The estimates are based on the information provided through the utility provider interviews and based on the engineering reports listed in Section 2. These costs are intended as an indicator of the general order of magnitude for the activities outlined. These costs should be used for site cost comparison purposes only. More detailed studies will be required to identify all factors associated with the actual costs required for extending the utility infrastructure and making the connections.

Table 4-3 – Payne Gap Utility Service Opinion of Probable Cost

Utility Items Included

Cost

BOP Others1

Water Costs associated with bringing water to the site will be associated with installation of on-site infrastructure - TBD during design

$0 $0

Sanitary Sewer

- Gravity Main / Force Main - Manholes - Lift Station(s) - 15% Construction Contingency - 30% Design/Admin/ROW/Legal/ Permitting

$0 $3.8 million

[City of Jenkins]

Natural Gas

Meter and Tap (incl. connection fees) $110,000

$0 16-inch main relocation (9,000 ft @ $455/lf) $4,100,000

Well closure $850,000

Electrical N/A (assumes no underground conduit required)

$0 $0

Telecommunications Installation of fiber optic cables Installation of copper cables $35,000 $0

UTILITY CONNECTION FEES $5,095,000 $3,800,000

TOTAL $8,895,000

1. Fee responsibility breakdown assumes the utility provider would contribute the portion of the costs listed above. If conditions change, BOP could potentially be responsible for all or portions of the “Others” fees.


12

Advantages:

• Water service has already been extended to the site with adequate pressure and modifications to the water supply are currently underway to meet the estimated BOP water demand

• The City of Jenkins to provide a connection to the existing sanitary sewer collection system at no cost to BOP

• Sufficient capacity available to supply electric power to the site at no cost to BOP

• Existing telecommunications service is adequate to meet minimum requirements of the proposed BOP facility, with minimal distance to the connection location

Disadvantages:

• Excavation and fill required to level property

• The existing 16-inch natural gas transmission line currently running through the proposed site would need to be relocated at the expense of BOP. Although the current pipeline is approximately 4,000 feet, it would require more than twice that distance to reroute the transmission line around the property. It would require at least two years to design, permit and construct the new line.

• There are two EQT gas wells on site that need to be relocated

A map of the existing utilities in the vicinity of the Payne Gap site is included in Figure 4-2.


13

Figure 4-2 - Existing Utilities at Payne Gap Site

Fiber splice location

Copper connection location Gateway Industrial Park


14

5.0 ALTERNATIVE ENERGY AND SUSTAINABILITY Part of Executive Order 13514, Federal Leadership in Environmental, Energy, and Economic Performance, requires Federal agencies to increase energy efficiency, conserve water, reduce waste, support sustainable communities, and leverage Federal purchasing power to promote environmentally responsible products and technologies. This reduction of demand from the natural environment and load back to the natural environment would benefit not only the local community, but also the proposed BOP federal correctional facility itself by reducing operating costs.

Without a detailed design for the proposed BOP facility, specific alternative energy designs and sustainability practices consistent with a new facility are difficult to identify at this time. However, some general practices aimed at the implementation of alternative energy sources and sustainability goals are discussed in this section, along with limitations associated with the sites. It is unlikely that the feasibility of specific practices would vary at the different proposed BOP facility sites that have been assessed. The viability and limitations are primarily associated with the entire region and any space constraints, which are comparable at both sites.

5.1 Alternative Energy Use of alternate or renewable sources of energy supports the Executive Order 13514 initiative by utilizing energy generated from natural resources that can be replenished naturally, without depleting the source. The two most widely recognized sources of renewable energy are related to solar and wind power. However, there are other sources of renewable energy such as biomass energy and geothermal systems that are gaining in popularity.

The National Renewable Energy Laboratory (NREL) is focused on the advancement of our nation’s energy goals, through the research and development of renewable energy and implementation of energy efficient systems. Through their research, NREL has performed numerous studies on the efficacy of different types of renewable energy sources. This section provides a discussion on available renewable energy sources, as well as the results of NREL’s research on their effectiveness in various parts of the country, and an assessment of potential use at the proposed BOP facility.

The renewable energy sources discussed in this assessment include:

• Wind Energy • Photovoltaics/Solar Power • Geothermal Systems • Biomass Energy


15

5.1.1 Wind Energy Wind energy is harnessed through catching naturally occurring wind with wind turbines and converting the wind’s energy into electricity. Turbines are typically installed on towers over 100 feet tall in order to harness higher wind speeds. Wind turbines can be installed individually, or in large groups, depending on their intended application, which can range from supplementing small portions of a facility’s energy consumption to providing the primary source of electricity.

In order for wind turbines to harness and convert wind into electricity there needs to be a consistent and sufficient amount of wind. NREL, in coordination with the Department of Energy’s Wind Program, published a wind resource map for the state of Kentucky. The wind resource map shows the predicted mean annual wind speeds at an 80-meter (m) [262.5-ft] height. Areas with annual average wind speeds of 6.5 meters per second and greater at an 80-m height are generally considered to be suitable for wind development. Figure 5-1 shows the wind resource potential at 80-m heights for Kentucky.

Figure 5-1 - Kentucky Wind Map

Source: NREL. Kentucky – Annual Average Wind Speed at 80 m. October 2010. http://apps.eere.energy.gov/wind/ windexchange/pdfs/wind.maps/ky_80m.pdf

Letcher County’s average annual wind speed falls below the 5.0 meters per second at the 80-m height. While the map is a nationally produced map and specific localized data was not gathered, it is generally accepted that wind power is an unlikely source for alternative energy for this part of the country.

Letcher County


16

5.1.2 Photovoltaics Solar power is an ever developing trend, with advances in the industry occurring regularly. Photovoltaics (PV) use semiconductor materials to convert sunlight energy into electricity. There are several types of collectors available for collecting the sun’s rays in different ways; some collect only direct rays and others collect both direct rays and reflected light. NREL has published a map of photovoltaic solar resources across the country. As seen in Figure 5-2, eastern Kentucky lies in a more moderate solar resource region. This does not necessarily indicate that PV is not a viable option for the new facility. There are a number of effective PV systems being utilized throughout the state of Kentucky.

Source: NREL. Photovoltaic Solar Resource of the United States. September 2012. http://www.nrel.gov/ gis/images/eere_pv/national_photovoltaic_2012-01.jpg

In discussion with a representative of the Kentucky Solar Partnership, solar power in eastern Kentucky can be a feasible option for supplementing power supply. While the energy generated from the solar panels would probably not be cost effective for the entire proposed BOP facility, solar panels could easily be utilized for providing power to the hot water tanks and smaller, energy-hungry appliances that would be utilized at the proposed BOP facility. Additionally, there are incentives and net metering alternatives to help reduce the demand from the energy provider. Therefore, it is recommended that PV systems be further investigated during the design of the new facility as a supplemental source of power.

Figure 5-2 - Photovoltaic Solar Resource of the U.S.


17

5.1.3 Geothermal Systems Geothermal systems use the temperature of the earth to heat and cool buildings. By installing a series of looped pipes deep into the ground, and pumping fluid through the system of pipes, geothermal systems utilize the relatively constant temperature of the earth to absorb and transfer heat to or from a building. Typically, the upper 10 feet of the Earth’s surface maintains a temperature of between 50° and 60°F (10° and 16°C). Geothermal heat pump systems include the system of pipes, a heat pump, and an air duct system. In the winter, the system pumps the heat into the buildings and in the summer the process is reversed to remove the heat from the building.

NREL has published a map of known hydrothermal sites and areas most conducive to the installation of geothermal systems. As seen in Figure 5-3, most geothermal reservoirs of hot water are located in the western states, as are the most favorable conditions for geothermal systems.

Although Eastern Kentucky is located in a “Least Favorable” zone, it does not preclude the BOP from implementing a supplemental geothermal system at the proposed correctional facility. These systems are relatively inexpensive to install and maintain, and are available in a wide range of capacities. This type of system would not be viable for providing all the heating and cooling needs of the proposed BOP facility, but such a system could supplement the building’s heating and cooling needs and should be considered during the design of the facility.

Figure 5-3 - Geothermal Resource of the U.S.

Source: NREL. Geothermal Resource of the United States. Oct. 2009. http://www.nrel.gov/gis/images/geothermal_ resource2009-final.jpg


18

5.1.4 Biomass Energy Biomass energy is the conversion of plant matter into either electricity or liquid or gaseous fuels. Common sources of biomass are grasses, agricultural crops, and forestry residues. The viability of using biomass energy as an alternative energy source is typically associated with the proximity of the source (plant material) to the point of use. NREL has published a map estimating the range of biomass resources available throughout the country. As seen below in Figure 5-4, the resources available in eastern Kentucky are minimal.

Source: NREL. Biomass Resources of the United States. Sep. 2009. http://www.nrel.gov/gis/images/map_biomass_ total_us_new.jpg

Although the map does not indicate that Kentucky has a wide supply of resources available to support a biomass energy system, a small system to supplement an existing gas supply system could be plausible, if there is a source within close proximity of the selected site. This option could be considered further during the design of the proposed BOP facility as a supplemental power source.

Figure 5-4 - Biomass Resources Available in the U.S.


19

5.2 Sustainability The concept of sustainability is often considered synonymous with environmental stewardship. Although green practices are integral to sustainability, the broader principle of sustainability implements the concept that development that meets the needs of the present should not compromise the ability of future generations to meet their own needs. The concept of the “triple bottom line” (TBL) states that success is measured not only by financial performance, but by balanced achievements in environmental stewardship, economic growth and social responsibility. The TBL is achieved when an integrated solution is found that simultaneously achieves excellence in these components, as opposed to finding tradeoffs among these areas.

The Environmental Stewardship component of the TBL focuses on practices such as reducing waste, minimizing carbon and water footprints, preventing pollution and conserving natural resources. However, to be truly “sustainable” as opposed to just “green,” it is important to also incorporate economic growth and social responsibility practices. Economic growth concepts focus on practices such as the use of local contractors and supplies, and creating and strengthening markets such as alternative energy. Social responsibility concepts focus on practices such as implementing fair labor practices or educating surrounding communities.

To implement these concepts of sustainability with respect to the construction of a new BOP federal correctional facility, there are some components that should be focused on during design and construction. Other practices can be implemented after facility construction and maintained as part of the facility’s standard operating procedures. During construction, recycled building materials should be utilized when available. Also, materials and labor should be selected from local vendors and suppliers, as applicable. As BOP begins to operate the facility, participation in programs promoting waste reduction, recycling, reuse and composting should be coordinated with the local Public Works and Public Health organizations. Some sustainability concepts that could be implemented with respect to reducing utility demands at the new site include:

1. Gray Water Disposal - The Letcher County Environmental Health Department indicated that there is availability to utilize gray water disposals for a portion of the sanitary sewer load. The gray water beds would be connected to the washing machine outfall only and could significantly reduce the amount of flow to the Whitesburg WWTP.

2. Water Reduction – To reduce the water demand at the new facility, the installation of water saving appliances such as low-flow toilets and high-efficiency clothes washers should be considered. Other considerations should be given when selecting landscaping alternatives. Xeriscaping refers to the selection of plants based on their drought tolerance and their ability to thrive without regular maintenance. Xeriscapes offer a viable alternative for attractive exterior space planning without consuming dwindling water resources and creating excessive cuttings or plant waste.

3. Green Roof - The inclusion of a “green” roof on top of the facility has the potential to improve the energy efficiency of the building by providing additional insulation and reducing electricity costs. Additionally, green roofs protect the roof membrane, which can result in a longer roof lifespan.


20

6.0 CONCLUSIONS The purpose of this Enhanced Utility Investigation Report was to assess the viability of providing utilities to the Roxana and Payne Gap sites for the proposed BOP federal correctional facility. Since many of the factors associated with the site work necessary to install the utility infrastructure are comparable at both sites, this comparison focuses on the cost to the BOP for bringing the utility connections to the edge of the properties. Potable water service has already been (or in the process of being) extended to both sites and the LWSD and the City of Jenkins are both amenable to providing wastewater collection lines to both sites. While the intention is to extend wastewater collection service to the sites at no cost to the BOP, it is likely that the Roxana site would require some cost sharing by BOP. Electric and telecommunications services are both readily available at both potential sites with some system extension and connection fees required for telecommunications services.

The one utility with significant impact on the costs associated with site development is natural gas. BOP does not want any wells or gas lines located on their property and therefore the construction of a new facility would require abandoning and closing a number of natural gas wells at Roxana or relocating an existing gas line around the property line at Payne Gap. The costs associated with these factors are significant and represent the primary utility cost difference associated with site selection. As seen in Table 6-1, the estimated cost to BOP for the connection at the Payne Gap site is significantly lower than the costs associated with Roxana. However, the relocation of the existing gas line will take approximately two years compared to the six months required to abandon the wells at Roxana.

Table 6-1 – Utility Connection - Probable Cost Comparison The two important factors associated with bringing utilities to the sites include cost to BOP and the time associated with constructing the infrastructure necessary to make the

connections to the various services. As discussed previously the costs and time associated with bringing all of the utilities, with the exception of natural gas, to the site are relatively comparable. The exception would be if BOP is required to provide some cost sharing for the extension of the wastewater collection system to Roxana. This could require approximately $1.4 million in BOP funding. The primary difference in cost is the natural gas modifications. As depicted in Table 6.1, the Roxana well closures are much more costly than the Payne Gap gas line relocation. However, with respect to time requirements, the relocation would require at least two years, while abandoning the wells would take about six months. These are the two key factors associated with the utilities that need to be considered during site selection.

After site selection is finalized, the BOP would have the opportunity to assess their options for implementing alternate energy systems and sustainability practices. These options and opportunities would need to be assessed in more detail during the design and operation and maintenance phases of this project. Although, it is not practical to install an alternative energy system to power the proposed BOP facility in its entirety, there are numerous systems that could potentially supplement the power provided to the site, and should be considered. Additionally, sustainability practices should be planned and coordinated with the local regulators to allow BOP to meet the goals set forth in Executive Order 13514 to increase energy efficiency, conserve water, reduce waste, and promote environmentally responsible products and technologies.

Location Utility Connection Costs (in millions)

BOP Others TOTAL Roxana/Meade Farm $14.4 $1.4 $15.8 Payne Gap $5.1 $3.8 $8.9


21

APPENDIX 1 – FIELD PHOTOGRAPHS

[Includes pictures at all identified sites prior to eliminating non-viable locations]


22


BOP – Letcher County **DRAFT** Utility Investigation Report

23

Photo #1 – Entrance Drive to Roxana Site

Photo #2 – Roxana Field


24

Photo #3 – Roxana Field looking West

Photo #4 – Buildings on Roxana Site


25

Photo #5 – Edge of Roxana Plateau

Photo #6 – Overview of Roxana Property


26

Photo #7 – Cell Tower on Van Fields Property

Photo #8 – Van Fields plateau


27

Photo #9 – Van Fields property looking northeast

Photo #10 – View of lower field at Van Fields


28

Photo #11 – Meadow Branch Entrance Drive

Photo #12 – Meadow Branch logging road


29

Photo #13 – Results of logging activity at Meadow Branch

Photo #14 – Logging Truck leaving Meadow Branch site


30

Photo #15 – Entrance drive to Payne Gap in heavy rain

Photo #16 – Entrance drive to Payne Gap in heavy rain


31

APPENDIX 2 – SITE INVESTIGATION UTILITY MEETINGS MEMO


32


Memo To: File

From: Curtis Lipsey

Cc: Deborah Henson

Date: May 9, 2011

Re: BOP – Letcher County Utility investigation

This memo covers the Utility Investigation Meetings held in Whitesburg Kentucky, week of May 2 – May 5. The utility investigation is one phase of the feasibility study for the four locations identified during the Reconnaissance Report by Louis Berger in 2008. The four sites identified are:

1. Roxana / Meade farm (ROX)

2. Van / Fields (VF)

3. Payne Gap (PG)

4. Meadow Branch (MB)

Attendees:

The following personnel were present at each of the site visits and utility meetings:

• Elwood Cornett – Letcher Co. Planning Commission (LCPC) • Jim Jones – LCPC consultant • Bridgettte Lyles – Bureau of Prisons (BOP) • Parke Ransom – BOP • Shaym Sharma – BOP • Deborah Henson – TEC Inc. • Curtis Lipsey – TEC Inc.

Site Visits: Site visits to the four potential sites were conducted on Tuesday, May 3, 2011. In addition to the above listed attendees, Jim Ward - County Judge / Executive and Joe DePriest – LCPC. The field visit to the Payne Gap site was conducted from inside the vehicles due to heavy rains; a short site walk was conducted at the remainder of the three sites.

Utility Meetings: The memo is divided into the discussions held for each utility type and provides a brief overview of the capacities, responsibilities, availability, and preliminary cost assumptions. Each meeting was attended by Mr. Elwood Cornett and Mr. Jim Jones, whom also provided input during several of the meetings.

WATER/SEWER:

Meeting Attendees:

Attendee ROX VF PG MB Date

Jim Ward – County Judge / Executive

W/S W/S W 5-4 Benny Hamilton – KRADD

Jamie Noe – Bell Engineering

Director of Letcher Co Water / Sewer

Matt Curtis – Nesbitt Engineering

S 5-5 Mayor G.C. Kinder – City of

Jenkins

Todd DePriest – City of Jenkins

Kevin Howard - Summit Engineering W/S W/S W/S 5-2

Brett Fisher – Summit Engineering

Mayor James Wylie – Whitesburg W/S W/S

• MB will be served by the Town of Pound VA, whom was unreachable for the meetings. • Judge Ward and the Director of Letcher Co Water and Sewer stated several times that

water and sewer service would be extended to ROX/VF/PG at no cost to the BOP if one of those sites was selected.

• ROX: Existing water lines are located within 5 miles of the site. • VF: Existing water lines are located adjacent to the site. • ROX/VF/PG: Regardless of whether the BOP facility is established, Letcher County is

planning on upgrading and connecting the county’s water system with neighboring counties and utility providers for consistency of service.

• ROX/VF/PG: Bell Engineering will perform an engineering estimate based on the estimated elevation of the facility to determine location and quantity of booster pumps to service the facility and elevated storage tanks.

• ROX/VF/PG: Bell Engineering to provide pdf maps of proposed county water systems. • ROX/VF/PG: Upgrades of nearby tanks and lines may be required in order to provide

service to the facility during times the elevated storage tank is off line for maintenance. • ROX: Sanitary Sewer is located approximately 9 miles of the site entrance by the

Parkway Inn. • VF: Sanitary sewer is located approximately 2.5 miles from the site entrance by the

Parkway Inn.

• ROX: The Whitesburg WWTP is located approximately 10 miles from the site entrance.

• VF: The Whitesburg WWTP is located approximately 4 miles from the site entrance. • ROX / VF: The Whitesburg WWTP was recently upgraded, partly in anticipation of the

BOP project, to handle 630,000 gpd and is currently receiving approximately half of the capacity. The plant was designed to be upgraded with additional modules to nearly 1,000,000 gpd.

• ROX / VF: The County is considering providing a dedicated sanitary line and system for the facility.

• Letcher County would prefer to know which site is preferred so they could focus their effort towards that location.

• The county does not have commercial rates, only residential, the connection fees are minimal and may be waived for the project.

• Mayor Wylie reiterated the planning commissions and Judge wards sentiments regarding provision of service to the selected site.

LETCHER COUNTY ENVIRONMENTAL HEALTH

Attendees:


Kevin Nichols – Letcher Co Health X X X X 5-3

• On-site wells for water service are no longer a feasible option in Letcher Co. • On-site sewer disposal (underground leech fields) would be significant in construction

and cost. • Basic calculations performed by Kevin Nichols resulted in the following numbers:

o 210,000 gal tank o 41,800 lf – 12-ft wide chamber beds o Based on 1400 bed facility

• On-site WWTP would be permitted through the State Division of Water, Letcher Co representative located in Hazard, KY – Damon White.

• On-site WWTP would require discharge to a blue line stream – def.: water running in stream all year long.

• State Division of Water also responsible for spray irrigation option, common in Kentucky.

• Graywater beds for washing machine discharge – 28,340 lf of 2-ft wide by 2-ft deep beds.

o Cross section of bed – 6-in stone / 4-in pipe / 6-in stone / 4-inch straw / topsoil

NATURAL GAS SERVICE

Attendees:


Don Goble – Troublesome Creek (TC) X 5-4

Jed Weinberg – Clean Gas Inc.(CG) X 5-5

Maurice Royster – EQT X X X X 5-5

Darryl Smith – EQT

• Each representative stated that most gas contracts regarding the wells and transmission lines have a clause that the gas company will relocate the transmission lines one time at no cost to the property owner. As long as the move is a property development action. Each representative was checking into the applicable properties for clarification.

• ROX: In addition to Troublesome Creek and Clean Gas, Kinzer Drilling (KD) also owns wells within the site. Kinzer has since been contacted and a conference call is being established.

• ROX: There are several wells (TC/CG/KD) and underground lines within the proposed site location. These wells would be located within the property of the future BOP facility and would either need to be capped and abandoned (at a cost) or agreements with the BOP made to continue operation. The lines will have to be adjusted to avoid the BOP facilities.

• VF: EQT has one gas well shown on the mining report map by Summit Engineering. EQT is preparing a cost estimate to abandon the well, including compensation for the well. TC has several wells located just outside of the proposed BOP property limits as estimated by Summit Engineering.

• PG: There are no wells located within the proposed property limits of the BOP facility.

• PG: EQT has a 16-inch gas main located through the center of the site that will need to be relocated. EQT is researching cost to relocate the gas main as well as legal responsibility.

• MG: EQT has a 4-inch gas line running through the proposed site location that will need to be relocated. EQT is researching cost to relocate the gas main as well as legal responsibility.

• MB: According to the Mining Report map produced by Summit Engineering, There are three wells by Columbia Natural Resources Inc./Triana Energy (CNR) within the proposed property limits. CNR has been contacted and we are waiting on return calls.

• According to Don Goble (TC) a small building for monitoring equipment would be located on-site near the meter and tap.

• TC gas wells and transmission lines (4-in) carry 1.23 BTU, zero to low sulfur, and can be routed directly into facility with no treatment processes.

• The wells in the ROX area have an estimated 20-25 year life.

• Approximate cost to abandon wells - $40,000 construction and $60,000-$80,000 compensation for lost revenues.

• CG: Jed Weinberg will pull comparable costs to the wells in the ROX site for cost estimating of abandoning the wells. Typical costs could run between $300,000 and $1,000,000 per well.

ELECTRICITY

Attendees:


Mark Abner – Cumberland Valley Elec. (CVE) X 5-4

Mike Laslo – Appalachia Electric (AEP) X X X 5-5

Mike L. – AEP X X X 5-5

• MB: New transmission lines (69-kV) would need to be run to site.

o Approx. 2-year construction time

o Temporary service could be provided today.

o Would locate a substation on site, 1-acre compound.

o Sole Source to BOP facility

o Would provide cable to master meter, up to BOP to provide conduit and connect facility to master meter.

• ROX / VF / PG: No on-site facilities would be required.

• AEP: Has 12 kV line adjacent to PG site

o Has 34 kV line adjacent to ROX /VF sites.

• ROX / VF / PG: Transmission lines would be run above ground

• ROX / VF / PG: 2 month estimated bill deposit required.

• AEP: Willing to give discounts for facility providing own “sustainable” power but would not buy back power.

TELECOMMUNICATIONS

Attendees:


Frank Dawahare – SouthEast Telephone (SE) X X X X 5-4

Roy Harlow – Intermountain Cable (IC) X 5-5

Kenny Samons – TVS Cable X X X 5-5

• SE: Provision of services to all four sites is not an issue. Service cost will depend on required bandwidth.

o T-1 lines are easily run, cost depends on whether T-1 is constant / dynamic / symmetrical / bonded?

o Depending on bandwidth, upgrades to system (signal boosters) may be required. Cost for installation shared amongst SE and BOP.

o Concern with service is reliability of upload speed.

• Roy Harlow @ intermountain Cable did not show for his meeting but called to apologize and stated we could work via phone and email.

• TVS: Can easily service the VF/PG sites but has questionable service to the ROX site.

o PG site can be provided with fiber optic and coax.

• TVS – suggested checking with ATT for service to ROX site.


Appendix E E-1 July 2015

APPENDIX E RESPONSES TO COMMENTS


E-2 Appendix E July 2015


Responses to Comments on the Draft Environmental Impact Statement USP and FPC Letcher County, Kentucky


Category Page Number

Federal/State/Local Agencies

US EPA Region 4 (Heinz Mueller) E-7 to E-26 US Department of the Interior, Office of the Secretary (Joyce Stanley) E-27 KY Department for Environmental Protection (Ronald Price) E-28 to E-30

Federal/State/Local Elected Officials

Steven Beshear (Governor of Kentucky) E-31 City of Jenkins E-32

Organizations and Business

Human Rights Defense Center E-33 to E-53 Bereans for Michael Brown (Quentin Savage) E-54 Mountain Comprehensive Health Corporation (Mike Caudill) E-55 to E-56 Palmer Engineering (Kevin Damron) E-57 Kentucky Highlands Investment Corporation (Jerry Rickett) E-58

Individuals

Robin Bowen-Watko (Whitesburg City Council) E-59 James Ison E-60 Nancy Fleming E-61 Annette Napier E-62 June Short E-63 Coleen Breeding E-64 Name Withheld E-65 Lori Pigman E-66 Name Withheld E-67 Connie Bates E-68 Kenneth Cornett E-69 Homer Pigman E-70 Name Withheld E-71 Toby Breeding E-72 Alex Williams E-73 Name Withheld E-74 David Clark (Appalachian Real Estate Group) E-75 Marlene Walters E-76 John Honeycutt E-77 Name Withheld E-78 Alecia Pratt E-79 Timothy Lewis E-80 James Fields E-81 Name Withheld E-82 Irene Thomas E-83 Jim McAuley (Letcher County Conservation District) E-84 Sue Grason E-85 Dixie Hall E-86 Name Withheld E-87 Name Withheld E-88 Maggie Watts E-89 Larry Hogg E-90




Rita Pratt (Whitaker Bank, Inc.) E-91 Freddie Bowling (Jenkins Independent Schools, Superintendent) E-92 Name Withheld E-93 Name Withheld E-94 Name Withheld E-95 David Narramore (Letcher Co. Tourism) E-96 Lisa Narramore E-97 Name Withheld (Jenkins Independent Schools) E-98 Name Withheld (Jenkins Independent Schools) E-99 Name Withheld (Jenkins Independent Schools) E-100 Name Withheld (Jenkins Independent Schools) E-101 Bennie McCall (City of Jenkins, City Administrator) E-102 Danny Ingram (Hazard Community and Technical College) E-103 Bonell Watts E-104 Tyler Smith E-105 Name Withheld E-106 Name Withheld E-107 Lovell Sexton E-108 Name Withheld E-109 Name Withheld E-110 Earlene William (Whitesburg City Council) E-111 Dauphus Day E-112 Name Withheld E-113 Tim and Carol Breeding E-114 James Fields (Little Zion Baptist Church, Pastor) E-115 John Reedy E-116 Name Withheld (Letcher County Public Schools) E-117 Bob Banks E-118 Terry Adams (County Magistrate) E-119 Name Withheld (Whitesburg Appalachian Regional Hospital) E-120 Roland Brown E-121 Brenda Day E-122 Gary Pratt E-123 Delena Miller E-124 Michelle Griffin (MCHC) E-125 Holly Caudill E-126 Juanita Collier Spangler (Letcher County Teachers Organization) E-127 Dwight Brockley (Whitesburg ARH) E-128 Nancy Campbell E-129 Name Withheld (Letcher County Board of Education) E-130 Shane Lyle (GRW) E-131 Mitchell Wright (Mitchell Wright Recycling) E-132 John Cain II E-133 Donald Wright E-134 Randi McCall E-135 Paul Fleming E-136 Name Withheld E-137 Melinda Whitaker E-138 Delana Banks E-139




James Kincaid E-140 Lee Caudill (Mountain Comprehensive Health Corporation) E-141 Robert Holcomb E-142 Mary Ann Whitaker E-143 Richard Whitaker E-144 Ricky Whitaker E-145 Stacie Collie E-146 Name Withheld (Lewis Electric Security Systems) E-147 Brad Collie E-148 Robin Kincer E-149 to E-150 Charles Sexton (Charles Sexton Trucking Inc.) E-151 to E-152 Elizabeth Jones E-153 to E-154 Name Withheld (Letcher County Chamber of Commerce) E-155 to E-156 Mary Ruth Wright E-157 to E-158 Stacy Isaac (Letcher County Schools) E-159 to E-160 Carol Ison (Cowan Community Action Group, Inc.) E-161 to E-162 James Perry (FBOP USP Lee) E-163 to E-164 Doug Adams E-165 to E-166 Name Withheld E-167 to E-168 Sherie Caudill (WARH) E-169 to E-170 Hettie Adams (Letcher County Fiscal Court) E-171 to E-172 Cristine Bolling (Letcher County Fiscal Court) E-173 to E-174 Rhonda Perry E-175 to E-176 Doris Frazier (Letcher County Fiscal Court) E-177 to E-178 Robert Meade (Kings Creek Volunteer Fire Department, Chief) E-179 to E-180 Crystal Hart E-181 to E-182 Name Withheld E-183 to E-184 Name Withheld E-185 to E-186 Leigh Blankenbeckley (Whitaker Bank) E-187 to E-188 Wendy Bentley (Community Trust Bank) E-189 to E-190 Randy Bailey (Letcher County Soil Conservation Supervisor) E-191 to E-192 Brenda Blair E-193 to E-194 Tara Damron E-195 to E-196 Name Withheld E-197 to E-198 Name Withheld (Kentucky Works Program/Big Sandy Area Development Dist.) E-199 to E-200

Name Withheld E-201 to E-202 Charles Frazier (Tom Short Ford, General Manager) E-203 to E-204 Abbetina Genty E-205 to E-206 Name Withheld E-207 to E-208 Name Withheld E-209 to E-210 James Craft (City of Whitesburg, Mayor) E-211 to E-212 Richard Lewis E-213 to E-214 Melanie Watts E-215 to E-216 Name Withheld E-217 to E-218 Name Withheld (Letcher County Board of Education) E-219 to E-220 Linda Watts E-221 to E-222 Margaret Lewis E-223 to E-225 Cathy Wright-Rose E-225 to E-226




Name Withheld (Jenkins Independent School Board) E-227 to E-228 Name Withheld E-229 to E-230 Alita Vogel (Letcher County Public Library) E-231 to E-232 Name Withheld (Letcher County Schools) E-233 to E-234 Regina Brown (Letcher County Schools) E-235 to E-236 Jolinda Wright E-237 to E-238 Stephanie Cassell (Jenkins Middle High School) E-239 to E-240 Name Withheld (Whitaker Bank) E-241 to E-242 Name Withheld (Letcher County Schools) E-243 to E-244 Kyle Smith (Knott County Water and Sewer) E-245 to E-246 Richard Smith E-247 to E-248 Marjorie Sparks E-249 to E-250 Randy Campbell E-251 Sherwood and Rhoda Ison E-252 Larry Whitaker E-253 Name Withheld E-254 Howard Stanfill (Kentucky Farm Bureau) E-255 Melissa McFall (Napa Auto Works/Childers Tire and Supply) E-256 Cathy Ingran E-257 Shirley Breeding E-258 Kate Walters E-259 Ralph Cornett E-260 Teresa Fleming (MCHC) E-261 Name Withheld E-262 Sandy Creech E-263 Name Withheld E-264 Margaret Hammonds (Whitaker Bank Inc.) E-265 Robert Hares E-266 Kennith Watts E-267 Amelia Kirby E-268 Addie Raleigh E-268 Elizabeth Sanders E-269 to E-270 James Craft E-271 Jimmie Farley E-272 Lisa Narramore E-273 Richard and Pat Yinger E-274 James Fields E-275 Carol and Louis Brown E-276 to E-277 Ann Hall E-278 Charles Holbrook, Jr. E-279 to E-280 Peggy Greer E-281 to E-282 Maura Ubinger E-283 Noam Brown E-284 Scott Parkin E-285 T. Reed Miller E-286 Tanya Nguyen E-287 Willie Dodson E-288 Benjamin Reynoso E-289 George Ball E-290




Libby Gho E-291 Toby Fraser E-292 Panagioti Tsolkas E-293

Form Letters

Form Letter 1 E-295 Form Letter 2 E-296 Form Letter 3 E-297 Form Letter 4 E-298 Form Letter 5 E-299 Form Letter 6 E-300 Form Letter 7 E-301 Form Letter 8 E-302 Citizen Petitions – received 1,251 signatures E-555 to E-592



1. The Preferred Alternative has been identified in Section 2.6 of the Final EIS.

2. Time schedules for the proposed project have not yet been established Detailed project schedules will only be determined if/when a Record of Decision has been issued and appropriated funds required for the project have been made available. Required funds for the proposed project have not yet been appropriated and the timing and availability of such funds is beyond the Bureau’s control.

3. The Bureau thanks you for reviewing the Draft EIS and has noted your comment.






1

2

3

4

5

6

7

8

9




10. See reply No. 1 above and Table ES-1 of the Executive Summary. The Preferred Alternative has been identified in Section 2.6 of the Final EIS as the Roxana site. The Bureau has conducted coordination with the Kentucky Transportation Cabinet, US Fish and Wildlife Service, and the US Army Corps of Engineers to outline minimization measures and develop appropriate mitigation for impacts which cannot be avoided. Chapters 4 and 5 discuss anticipated impacts, agency coordination and proposed mitigation measures. Appendix A contains agency correspondence.

9

10




1






1

2

3



4. These BMPs have been added to the Air Quality sections of the Final EIS.

4




1






1

2

3



1. In accordance with the National Environmental Policy Act, the Bureau has evaluated a reasonable number of alternatives based on the project needs. The National Environmental Policy Act and the Council on Environmental Quality (CEQ) do not identify that a set number of alternatives be evaluated, just that a reasonable number of alternatives are evaluated. CEQ guidance specifically states "What constitutes a reasonable number of alternatives depends on the nature of the proposal and the facts in each case.” The process of alternatives evaluation began during the feasibility study and four alternatives were considered. Based on the outcome of that study it was determined that there were two reasonable alternatives that would meet the requirements of the Bureau and the proposed project. Chapter 2 discusses the alternatives development for the project.

1



2. The Bureau thanks you for reviewing the Draft EIS and has noted your comment. The Bureau is responsible for housing inmates sentenced by the federal court system. The Bureau is not the agency responsible for developing sentencing guidelines or alternatives to current sentencing guidelines.

3. Placement of an inmate depends on numerous factors as outlined in the Bureau’s Program Statement 5100.08. Attempting to locate the inmate within the region of origin provides greater opportunity for family to visit.

2

3



4. Public involvement for this Final EIS is in full compliance with NEPA requirements. Section 1.7.4 of the Final EIS details public involvement activities that occurred for the project. All comments received at any point during the development of the Draft EIS and Final EIS are part of the project Administrative Record.

3

4



4



5. No health and safety impacts are anticipated. Based on review of coal ash sites, none are located in Letcher County near the proposed alternatives (http://content.sierraclub.org/coal/disposal-ash-waste, http://www.epa.gov/osw/nonhaz/industrial/special/fossil/ccrs-fs/).

Additionally no slurry ponds are located within Letcher County (http://www.epa.gov/osw/nonhaz/industrial/special/fossil/surveys2/index.htm)

4

5

http://content.sierraclub.org/coal/disposal-ash-waste

http://content.sierraclub.org/coal/disposal-ash-waste







6. The proposed project is not located near coal mining waste facilities. There are no active coal mines on either of the proposed sites. Studies, including geotechnical, have been conducted to determine extent of excavation and grading activities to remove mine spoil and prepare the site for development.

The proposed facilities would be developed and operated in accordance with all applicable federal and state laws and regulations, including health and safety as well as environmental requirements. No impacts to the health and safety of persons (inmates, staff, visitors, or contractors) is anticipated as a result of the project or past mining activities on the proposed site.

6



6



7. Kentucky's Energy and Environment Cabinet, Department for Environmental Protection, Division of Water is responsible for protecting the public's potable drinking water supply. 401 Kentucky Administrative Regulations (KAR) Chapter 8 outlines the requirements for public water systems. This includes both treatment of water for distribution to the public, as well as, quality assurance procedures. Under 401 KAR Chapter 8, public water supplies are required to submit monthly reports to the Division of Water. If there are violations, recommendations are issued to the community. The Bureau would follow any recommendations regarding treatment of potable water by the Division of Water.

6

7



8. The following text has been added to the Final EIS regarding radon:

Radon is naturally occurring, colorless, odorless, radioactive gas produced by the decay of uranium in rock and soil. Radon is a known carcinogen, responsible for increasing the risk of lung cancer when inhaled. Electrically charged radon atoms can attach to indoor air dust particles. Subsequently, these dust particles may be inhaled and adhere to lining in the lungs. The deposited atoms decay by emitting radiation that has the potential to cause cellular damage. Typically, outside air contains very low levels of radon (USEPA 2015), but radon tends to accumulate in enclosed indoor spaces. When present, radon gas would typically concentrate in relatively airtight buildings with little outside air exchange.

Mitigation

Although there are no federal regulations that mandate an acceptable level of radon exposure, the USEPA recommends the voluntary radon action level developed and issued by the American Society for Testing and Materials International (ASTMI), Standard Practice for Installing Radon Mitigation Systems in Existing Low-Rise Residential Buildings, ASTMI E-2121. Radon resistant construction techniques may be used to mitigate potential impacts from radon. In addition, periodic testing of the facility may be conducted to verify that no unacceptable radon gas buildup occurs. Installation of radon mitigation systems may also occur, as appropriate.

9. Environmental Justice guidance (Executive Order 12898) directs federal agencies to address “disproportionately high and adverse” human health or environmental effects of its actions upon minority and low income populations. The Bureau does not concur with the assertion that federal

7

8

9



inmates of mixed backgrounds (as to ethnicity, race, and income) to be housed in the proposed facilities constitute either a minority or low income population for purposes of EO12898. However, even assuming they may, neither “disproportionately high” nor “adverse” human health or environmental effects would result to the inmate population as a result of the proposed project.

Currently, there are no plans for a UNICOR operation at this facility, thus no additional information is available as to the type of operation that might be located there in the future. If UNICOR does operate at this location in the future, all applicable environmental laws and regulations will be adhered to and enforced.

10. Chapters 4 and 5 of the Final EIS discuss the affected environment, environmental consequences, and mitigation if there are impacts. Additionally, Appendix A of the Final EIS includes agency correspondence that describes coordination regarding necessary mitigation.

9

10



11. As stated in Sections 4.8 and 5.8 of the Final EIS, LWSD is the service provider for the area in which the proposed alternatives are located. The Bureau would receive potable water from the LWSD; therefore, as described in the Final EIS the capacity of the LWSD is what must be evaluated to determine if they can supply the proposed facility. Mitigation for proposed impacts is discussed in Chapters 4 and 5 of the Final EIS.

10

11



12. Permitted capacity is the amount an entity is permitted to use or supply, in this case the provider, LWSD, is permitted to use 4,000,000 gallons of water per day.

13. The Draft EIS stated in Chapters 4 and 5 that a Phase I bat habitat survey had been conducted and was currently under review by USFWS. The Draft EIS further stated that there is summer habitat at both alternative sites and winter habitat at the Payne Gap site. The Draft EIS also stated that coordination would be ongoing with USFWS to determine appropriate mitigation. The Bureau met with USFWS on May 20, 2015 to discuss mitigation. Chapters 4 and 5 have been updated to reflect the additional coordination and Appendix A contains agency coordination efforts.

11

12

13



14. Appropriate coordination with state and federal agencies occurred to determine if other threatened and endangered species had the potential to be affected. Agency coordination efforts are included in Appendix A of the Final EIS.

15. Please see response to comment 13. 14

15



16. Chapters 4 and 5 of the Final EIS discuss the affected environment, environmental consequences, and mitigation if there are impacts. Additionally, Appendix A of the Final EIS includes agency correspondence that describes coordination regarding necessary mitigation.

The Draft EIS stated in Chapters 4 and 5 that a Phase I bat habitat survey had been conducted and was currently under review by USFWS. The Draft EIS further stated that there is summer habitat at both alternative sites and winter habitat at the Payne Gap site. The Draft EIS also stated that coordination would be ongoing with USFWS to determine appropriate mitigation. The Bureau met with USFWS on May 20, 2015 to discuss mitigation. Chapters 4 and 5 have been updated to reflect the additional coordination and Appendix A contains agency coordination efforts.

The Final EIS mitigation text for threatened and endangered species has been updated to reflect the additional agency coordination that has occurred and updated mitigation requirements based on this coordination.

The amount paid into the mitigation fund is directly related to the time of year the habitat is removed, per USFWS Indiana Bat guidelines.

15

16



17. Records of communication with law enforcement and emergency service providers have been included in Appendix A. The Bureau has coordinated appropriately with these providers to determine what affect the proposed action may have on their ability to provide service.

Prisons do not bring litigation. Assessing related criminal and civil court filings for comparable Bureau facilities is not part of the proposed action.

The Bureau’s Employee Assistance Program (EAP) is a benefit to all full-time employees. This program provides brief counseling, consultation, and referral services to all staff and their immediate family members. These free services can be used to address any variety of work-related or personal concerns. Each facility also has its own Crisis Support Team (CST) which operates at the discretion of the warden, to attend to the needs of staff and their family during a crisis. Crises can include an individual staff member experiencing a family emergency (e.g., sick child, medical emergency, etc.) to opening and operating a Family Support Center for all staff and their families following a natural disaster. Both programs operate with the support of other regional institutions and resources, as well as the BOP's Central Office. Together, EAP and CST aim to address most of the mental health needs of its staff, and can be accessed 24/7.

16

17



18. Currently, there are no plans for a UNICOR operation at this facility, thus no additional information is available as to the type of operation that might be located there in the future. If UNICOR does operate at this location in the future, all applicable environmental laws and regulations will be adhered to and enforced.

The Final EIS addresses environmental justice in accordance with EO 12898 and NEPA. No low-income, minority, or Indian tribes would be disproportionately impacted and no disparate or significant adverse impacts are anticipated as a result of the proposed action as described in Sections 4.3 and 5.3 of this Final EIS.

17

18

19



19. This is exclusively under legislative and/or election official’s oversight and beyond the Bureau's jurisdiction or control. With regard to potential dilution or other voting impacts, the incarceration of non-voting inmates at the proposed facility, regardless of where they come from, is believed to be a less than significant impact.

20. Cumulative impacts are evaluated for impacts an agency’s proposed action may have on a resource when an impact from the proposed action results. That impact is then compared to other past, present, or reasonably foreseeable future projects which may have impacts to that same resource resulting in the agency’s proposed action contributing to a cumulative impact to the resource. If the agency’s proposed action does not impact a resource it will not contribute to a cumulative impact. If an agency’s proposed action does impact a resource then, if there are other projects to compare it to, a cumulative impact assessment is done. Within the area of the proposed alternative locations, little to no development has occurred or is anticipated to occur in the future based on coordination with the Letcher County Planning Commission and the Socioeconomic Development Office. Potential cumulative impacts associated with the Bureau’s proposed action are discussed in Chapter 8.

21. NEPA requires that the EIS evaluate the proposed impacts associated with the proposed action outlined in the EIS. The other facilities were evaluated in separate environmental documents which evaluated the proposed impacts associated with the individual projects.

20

21

22

23



23. As stated in the EIS, Section 1.5 Purpose and Need, the purpose of the project is to increase capacity and reduce overcrowding. The No Action Alternative does not meet the purpose and need of the proposed action.



24

25

26



1. The Bureau thanks you for reviewing the Draft EIS and has noted your comment. 1




1




2. The preferred alternative for the proposed action has been identified in Chapter 2, Section 2.6-Preferred Alternative of the Final EIS. At this time there is no information regarding construction schedule.

1

2




1



1. The Bureau thanks you for reviewing the Draft EIS.




1



1. The Bureau thanks you for reviewing the Draft EIS.




1





1

2




1





1

2




1





1

2




1






1

2

3




1





1

2




1





1

2




1





1

2




1



1. The Bureau thanks you for your participation.




1





1

2




1





1

2




1





1

2




1





1

2




1





1

2




1





1

2




1




1

1



1



1. The Bureau appreciates your participation and would meet with families to discuss the potential acquisition of properties.

1




3. The Bureau would not impact cemeteries.

4. Property that is acquired by the Bureau for the facility becomes the Bureau’s property and for safety and security reasons the public cannot have access to the property.

5. Figure 2-3 depicts the distance between the proposed facility and nearby residences.

6. The Bureau would not impact or relocate cemeteries.


2

3

4

5

6

7




1





3




1




2




1




2





1

2





3

4




1





2

3




1





2

3




2. Owners of land acquired by the Federal Government are entitled under federal law to “just compensation” which generally means the Fair Market Value (FMV) of the property. The FMV of each property acquired would be determined by an appraisal conducted pursuant to federal law and in accordance with the Uniform Appraisal Standards for Federal Land Acquisitions (2000 edition). To the extent a property to be acquired contains commercial timber, the appraisal/FMV determination would typically include the timber value as a component of the entire property value. Should timber be removed/harvested by a landowner prior to acquisition, the resulting appraised value/FMV would generally be reduced to reflect the recent timber removal/harvest. Surrounding landowners, as well as owners of land acquired by the Federal Government, are generally not entitled to consequential damages or damages for any contingent or potential future damages.

1

2




2

3




1




1

2




1




2. Traffic impact studies were conducted for both sites. Chapter 5, Section 5.5 in the Final EIS discusses traffic and roadway conditions, potential impacts, and proposed mitigation.

1

2




2

3




1





1

2




3




1






2

3

4




1



1. Section 4.8 of the Final EIS discusses infrastructure and utilities including solid waste. As described in the Final EIS, the county would pick up solid waste from the facility. The Bureau would pay the rate assessed by the county for disposal of their solid waste.

1





2

3




1





1

2




3




1





3



1. The Bureau would not impact cemeteries.


1

2




4. The Bureau thanks you for your participation and has noted your comment.

5. The career opportunities brochure has been forwarded to your address since there is no address provided for your mother.

2

3

4

5




1










1

2

3

4

5

6

7

8




1






1

2

3

4




1







2

3

4

5




1




2




1



1. Owners of land acquired by the Federal Government are entitled under federal law to “just compensation” which generally means the Fair Market Value (FMV) of the property. The FMV of each property acquired would be determined by an appraisal conducted pursuant to federal law and in accordance with the Uniform Appraisal Standards for Federal Land Acquisitions (2000 edition). To the extent a property to be acquired contains commercial timber, the appraisal/FMV determination would typically include the timber value as a component of the entire property value. Should timber be removed/harvested by a landowner prior to acquisition, the resulting appraised value/FMV would generally be reduced to reflect the recent timber removal/harvest. Surrounding landowners, as well as owners of land acquired by the Federal Government, are generally not entitled to consequential damages or damages for any contingent or potential future damages.

1





1

2






1

1

2



1. The Bureau thanks you for reviewing the Draft EIS and has noted your comment. Section 1.7.4 of the FINAL EIS has been revised to reflect that many comments were received, the majority of which were in support of the project; however, all comments, positive and negative that have been submitted have been noted and will be considered by the Bureau in connection with issuance of a Record of Decision regarding the proposed action.

1



2. The Employee Assistance Program (EAP) is a benefit to all full-time employees. This program provides brief counseling, consultation, and referral services to all staff and their immediate family members. These free services can be used to address any variety of work-related or personal concerns. Each facility also has its own Crisis Support Team (CST), which operates at the discretion of the warden, to attend to the needs of staff and their family during a crisis. Crises can include anything as small as an individual staff member experiencing a family emergency (e.g., sick child, medical emergency, etc.) to something as large as opening and operating a Family Support Center for all staff and their families following a natural disaster. Both programs operate with the support of other regional institutions and resources, as well as the BOP's Central Office. Together, EAP and CST aim to address most of the mental health needs of its staff, and can be accessed 24/7.

3. The Bureau thanks you for reviewing the Draft EIS and has noted your comment. The Bureau is not the agency responsible for sentencing guidelines nor does it participate in the sentencing of convicted felons. The Bureau's responsibility is for housing those inmates sentenced within the federal court system.

No health and safety impacts are anticipated.

The Bureau provides healthcare services within their institutions. Under the Proposed Action, the Bureau would employ healthcare staff to meet the medical, dental and mental healthcare needs of inmates. In the event of a medical emergency that cannot be accommodated at the facility, coordination with local health care officials indicates that emergency treatment of an inmate can be accommodated by the local hospitals with no impact to the local healthcare system, as described in Chapter 4, Section 4.4.2.3 of the FINAL EIS.


2

3

4

5






1

2

3




1






1

2

3




2. The Bureau is not the agency responsible for sentencing guidelines nor does it participate in the sentencing of convicted felons. The Bureau's responsibility is for housing those inmates sentenced within the federal court system.




1

2

5

3

4




1




2. The stream impacts in Chapters 4 and 5 of the FINAL EIS are correct. The summary table in the Executive Summary reflected inaccurate numbers. These numbers have been revised to correspond to the numbers in Chapters 4 and 5. Engineering design for the proposed facility will require the development of stormwater management to manage stormwater on-site and minimize potential impacts stormwater runoff may have on nearby streams. Additionally, measures would be taken to keep as much of the forested area associated with the sites and the Bureau would evaluate re-vegetation of areas post-construction to reduce runoff, erosion and sedimentation.

1

2



3. The Bureau thanks you for reviewing the Draft EIS and has noted your comment. The site described in your comment was not offered to the Bureau by the property owner.


3

4




The Bureau has identified the Preferred Alternative in Section 2.6 of the FINAL EIS.

1



1



1. The Bureau thanks you for reviewing the Draft EIS and has noted your comment

2. The Bureau thanks you for reviewing the Draft EIS and has noted your comment

1

2






1

2

3






1 2

3






1

2

3






1 2

3






1

2

3





1

2




1



Form Letter 1


Following are all the signed Form Letter 1’s that were received.

1



Form Letter 2



1



Form Letter 3



1



Form Letter 4



1



Form Letter 5



1



Form Letter 6



1



Form Letter 7



1



Form Letter 8



1


Appendix F F-1 July 2015

APPENDIX F TRAFFIC IMPACT STUDY


F-2 Appendix F July 2015


Federal Correctional Facility

Environmental Impact Statement

Draft Traffic Impact Study

Prepared for:

FEDERAL BUREAU OF PRISONS

Prepared by:

PARSONS BRINCKERHOFF

Revision History: Revision Date Description Submitted by

1 2/26/15 Revisions by Cardno L. Walker 2 3/25/15 Revisions by Federal Bureau of Prisons L. Walker 3 4/23/15 Revisions by Kentucky Transportation Cabinet L. Walker

Letcher County i Traffic Impact Study Federal Correctional Facility April 2015

TABLE OF CONTENTS

1.0 Introduction ..................................................................................................................... 1 1.1. Study Purpose and Objectives ............................................................................. 1

1.2. Summary of Proposed Action ............................................................................... 1

1.3. Study Area ................................................................................................................ 1

1.4. Data Collection ....................................................................................................... 2

2.0 Existing Conditions and Level of Service...................................................................... 3

3.0 Development .................................................................................................................. 4

4.0 Trip Generation ............................................................................................................... 7

5.0 Trip Distribution and Assignment ................................................................................... 7

6.0 Traffic Forecasting and Analysis ................................................................................... 8

7.0 Construction Traffic Impacts on Roadway ................................................................... 9

8.0 Recommendations / Conclusion ................................................................................ 13

Appendix A – Traffic Counts Appendix B – HCS Output Appendix C – TIS Figures Appendix D – ESAL Calculations

Letcher County ii Traffic Impact Study Federal Correctional Facility April 2015

LIST OF FIGURES Figure 1-1: Study Area ..................................................................................................................... 2 Figure 3-1: Payne Gap Site Development Plan .......................................................................... 5 Figure 3-2: Roxana Site Development Plan ................................................................................. 6 LIST OF TABLES Table 2-1: AM Peak Period ............................................................................................................. 4 Table 2-2: PM Peak Period ............................................................................................................. 4 Table 4-1: Trip Generation Results ................................................................................................. 7 Table 6-1: Future Year (2020) AM Peak Period ........................................................................... 8 Table 6-2: Future Year (2020) PM Peak Period ............................................................................ 8 Table 6-3: Payne Gap Site Intersection Analysis ........................................................................ 8 Table 6-4: Roxana Site Intersection Analysis ............................................................................... 9 Table 7-1: FHWA Vehicle Classification (from FHWA) .............................................................. 11

Letcher County 1 Traffic Impact Study Federal Correctional Facility April 2015

1.0 INTRODUCTION

1.1. Study Purpose and Objectives

Parsons Brinckerhoff (PB) was contracted by the Federal Bureau of Prisons to conduct a Traffic Impact Study (TIS) and provide related traffic engineering services in the evaluation of two alternative sites for a proposed federal correctional facility in Letcher County, Kentucky. The purpose of this TIS is to analyze the traffic operating conditions in the vicinity of the new facility. Specific attention will be given to the proposed access points that will serve the development. It is the goal of this document to follow the guidelines1 established by the Kentucky Transportation Cabinet (KYTC) on traffic impact studies that impact state-maintained facilities. 1.2. Summary of Proposed Action

The “Proposed Action” is a proposed federal correctional facility. It is expected that during construction the Proposed Action would temporarily add the following types of trips to the highway network:

Construction worker commuting trips Trips involving the delivery and removal of construction equipment

Following construction, the proposed facility would add traffic to the surrounding roadway network on a recurring basis. This traffic increase would include employee commuting trips, plus additional trips (such as the transfer of inmates, inmate visitors, delivery of supplies and equipment, etc.) that would not necessarily coincide with peak commuting periods. The proposed facility would have a staff of 300 full-time employees. The employees would be expected to add trips during peak commuting periods. Based on hourly count data from KYTC, existing peak periods are 7:00 – 9:00 AM and 3:00 – 5:00 PM on a typical weekday. 1.3. Study Area

Two potential sites have been identified for the Proposed Action. The first site is referred to as the Payne Gap Site. It is located approximately 7.5 miles to the east of Whitesburg, Kentucky. The site is accessed from US 119 and is located east of Bottom Fork Road (KY 3406) and west of Talman Drive. The other site is referred to as the Roxana Site. It is located approximately 7.5 miles to the west of Whitesburg, Kentucky. The site is located south of KY 588 and to the west of KY 160. The site locations are shown in Figure 1-1.

1 2012 KYTC Traffic Impact Study Requirements; http://transportation.ky.gov/Permits/Documents/2012%20POLICY-TIS%20Requirements.pdf


Figure 1-1: Study Area

Access to the Payne Gap Site is expected to be from US 119 only. Access to the Roxana Site is expected to be from KY 588 just east of Tolson Creek 1.4. Data Collection

Data (including Annual Average Daily Traffic (AADT) volumes) collected for this TIS was obtained from two different sources:

1) Existing 48-hour traffic counts provided by the KYTC for routes located near the study sites. These include the following stations:

o US 119 – Station 272: 2013 AADT = 6,010 o KY 160 – Station 755: 2014 AADT = 550 o KY 588 – Station 796: 2014 AADT = 330 o KY 2036 – Station 776: 2012 AADT = 80

2) Supplemental 48-hour classification counts at four locations conducted January

19 – 21, 2015. These counts were performed at the following locations:


o US 119 (east of intersection with KY 805) o KY 160 (between KY 2036 and KY 588) o KY 588 (Big Branch Tolson Creek) o KY 588 (just north of Paces Branch Rd)

All count data is included in Appendix A. 2.0 EXISTING CONDITIONS AND LEVEL OF SERVICE

For this analysis, the Highway Capacity Software 2010 package (HCS 2010) based on the 2010 Highway Capacity Manual was used to assess the peak period traffic operating conditions for the following study segments that are expected to be most impacted by the Proposed Action:

US 119 KY 588

US 119 is a four-lane facility with a flush median, and is therefore evaluated as a multi-lane highway. KY 588 is a two-lane facility and is considered to be a Class II highway2. Class II highways include lower speed collector roadways and roads primarily designed to provide access. Levels of service for Class II highways are defined only in terms of a vehicle’s percent time spent following. Percent time spent following is the average percent of total travel time that vehicles must travel in platoons behind slower vehicles because of inability to pass on a two-lane highway3. Average travel speed is not considered since drivers typically will tolerate lower speeds on a Class II facility because of its function as an access roadway (serving shorter trips and fewer through trips). For each study segment, the volume to capacity ratio (v/c) as well as the resulting levels of service (LOS) was determined. It was assumed that LOS D or better would be acceptable for KY 588 (rural mountainous collector) based on guidelines from the AASHTO A Policy on Geometric Design of Highways and Streets (6th Edition). For US 119 (rural level arterial), LOS B is the desired LOS based on the same guidelines. Also, it should be noted that all HCS 2010 output is included in Appendix B. The major software inputs require roadway geometry (i.e. lane and shoulder widths), as well as traffic volumes by direction. The roadway geometry for the existing conditions was determined from the HIS database as well as aerial photos. The traffic volumes were determined from the data collection efforts. Based on previous hourly counts from KYTC as well as the hourly counts conducted for this study, the peak hours on a weekday were noted between 7:00 – 9:00 AM and 3:00 – 5:00 PM. The highest hourly volumes from the counts were used for this analysis from these time periods. Table 2-1 and Table 2-2 present the v/c ratio and level of service for the study area segments for both the AM and PM peak periods. 2 Highway classifications for two-lane facilities based on the Highway Capacity Manual 2010. 3 Highway Capacity Manual 2010


Table 2-1: AM Peak Period

Segment v/c ratio LOS

US 119 0.08 A KY 588 0.04 A

Table 2-2: PM Peak Period


US 119 0.09 A KY 588 0.02 A

Traffic volumes are very low on KY 588 (less than 50 vehicles per hour). Based on the analysis of the v/c ratio, there is plenty of available capacity along these segments. A ratio of 1.0 is considered at capacity and all ratios shown are substantially below that threshold. 3.0 DEVELOPMENT

A copy of the development plan for the correctional facility or United States Penitentiary (USP) was provided by the Federal Bureau of Prisons. Included in this development plan were locations of site access, parking areas and the internal roadway network. The anticipated completion date is 2020. Figure 3-1 and Figure 3-2 provides the preliminary development plans for informational purposes only.


Figure 3-1: Payne Gap Site Development Plan


Figure 3-2: Roxana Site Development Plan


4.0 TRIP GENERATION

The primary development under consideration is a federal correctional facility. A review of the Institute of Transportation Engineer’s (ITE) Trip Generation Manual (9th Edition) does provide data for a similar land use (Land Use 571). Two values are presented for both the AM and PM Peak hours: 1) Number of trips generated in the peak hour of the generator; and, 2) In/out distribution percentages of those trips. The variable these values are based on is the number of employees. Background information provided by Cardno during the scoping process of this study noted that the proposed facility would have a staff of 300 full-time employees. Employees would be expected to add trips during peak commuting periods. Utilizing this information, Table 4-1 provides a summary of the trip generation results. As both sites would have the same number of employees, these numbers are valid for both the Payne Gap and Roxana sites.

Table 4-1: Trip Generation Results

Variable AM Peak PM Peak

Trips Generated 156 204 Percent In 62% 27% Percent Out 38% 73%

A higher number of trips are expected to be generated in the PM Peak period based on the previous studies performed and documented in the ITE Trip Generation Manual of traffic patterns associated with a federal correctional facility. There are expected to be other trips to / from the sites that would not necessarily coincide with peak commuting periods. These trips include transfer of inmates, inmate visitors, and delivery of supplies and equipment. Given the low volumes on both KY 588 and US 119, there is expected to be little to no impact related to these off-peak trips. The peak periods evaluated represent the “worst case” scenario for traffic impacts to the existing routes. 5.0 TRIP DISTRIBUTION AND ASSIGNMENT

The data collected for this study was used to determine directional splits of traffic entering / exiting the sites. Only trips generated by the site are included in the distribution and assignment. It is assumed that no pass-by trips are expected for this study given the proposed development. Due to the unique nature of the site as well, it is expected that there will not be any internal capture trips for this study. Appendix C provides a summary of the trip generation / trip distribution for this study.


6.0 TRAFFIC FORECASTING AND ANALYSIS

The next step involved forecasting the traffic volumes for year 2020 (anticipated opening year). This was done using historical traffic trends of nearby KYTC count stations. The stations included 272 (US 119) and 796 (KY 588) in Letcher County. The change in traffic volumes from year to year resulted in an average decline for each of these stations ranging from 0.68% to 6.35% per year. Given the trending decline in growth, the conservative estimate for traffic impacts in the future would be to assume no growth at this point. Therefore, volumes evaluated for the 2020 year analysis are assumed to be the same as those used for the current year analysis. Table 6-1 and Table 6-2 presents the level of service for the two segments previously evaluated utilizing the assumed 2020 base year volumes with the added trip generation due to the new prison facility. Table 6-3 and Table 6-4 provide analysis for the new intersections created by the new access road to the prison. The initial analysis assumed the intersections were STOP controlled on the minor approach (access road) with the mainline (KY 588 and US 119) left at free-flow conditions. No turn lanes were assumed for the initial analysis as well to provide a baseline for operations.

Table 6-1: Future Year (2020) AM Peak Period


US 119 0.10 A KY 588 0.09 B

Table 6-2: Future Year (2020) PM Peak Period


US 119 0.11 A KY 588 0.10 B

Table 6-3: Payne Gap Site Intersection Analysis

Approach

AM Approach

Delay (sec)

AM Approach

LOS

PM Approach

Delay (sec)

PM Approach

LOS

Westbound 8.2 A 8.0 A Northbound 12.3 B 13.3 B


Table 6-4: Roxana Site Intersection Analysis

Approach

AM Approach

Delay (sec)

AM Approach

LOS

PM Approach

Delay (sec)

PM Approach

LOS

Westbound 7.5 A 7.4 A Northbound 9.6 A 9.7 A

As shown, the intersections at both sites operate at an acceptable LOS. Based on these volumes, no separate turn lanes are warranted at this time. A review of traffic signal warrants (per the Manual on Uniform Traffic Control Devices (MUTCD)) found that none of the volume warrants were met (Warrant 1: Eight-Hour Vehicular Volume, Warrant 2: Four-Hour Vehicular Volume, and Warrant 3: Peak Hour). Therefore, installation of a traffic control signal is not warranted at this time. After consultation with the Kentucky Transportation Cabinet (KYTC), a recommendation was made to consider constructing a left turn lane along US 119 and KY 588 into the site. This consideration was made base on safety implications – looking to reduce the possibility of a following vehicle rear-ending the turning vehicle. It may be necessary to move some of the grade drains in the middle of the median along US 119 depending on the exact entrance to the access road. 7.0 CONSTRUCTION TRAFFIC IMPACTS ON ROADWAYS

An additional task as part of this evaluation includes determining the construction impacts on the roadways accessing the sites. First, an analysis of the existing pavement of the two key routes was conducted using construction plans (as available) from KYTC. US 119 Construction traffic may come from the east (Jenkins area) or west (Whitesburg area) along US 119. US 119 is a main route in Eastern Kentucky and should be able to support all associated construction traffic for the development of the site. The evaluation of the pavement and the supportable load is given below. Archived design plans for the section of US 119 near the proposed site are from 1971. The design plans note the following:

24” Stabilized Rock Roadbed 11” Crushed Stone Base 2.75” Asphalt Base


2.75” Asphalt Base 1” Asphalt Surface

An Equivalent Single Axle Load (ESAL) is a measure of pavement damage and is used in pavement design. The ESALs (based on future year traffic and truck volumes) is 2,400,000. According to the KYTC calculation sheet, the current design should be acceptable up to 7,000,000 ESALs. The ESAL calculation sheet is included in Appendix D. It should be noted that US 119 is a state-maintained coal haul route and has a maximum gross vehicle weight of 80,000 lbs per KYTC Truck Weight Classification. Therefore, this route is intended to accommodate heavy truck traffic. KY 588 The construction traffic would likely access this site from Whitesburg. This route follows KY 3401 to KY 588 / KY 160. It is a total of approximately 10 miles. The available archived plans for KY 588 show it as a gravel road. However, it has been paved since then though those plans were not available for review. Through email communication with KYTC it was confirmed that no design plans were available. Therefore, for purposes of this study, an assumption was made that the pavement design of KY 588 would be less than that of a designated US Route such as US 119. It was further assumed that KY 588 (as a rural minor collector road with given traffic volumes and truck traffic) would have a pavement design as follows:

4” Crushed Stone Base 3.00” Asphalt Base 3.00” Asphalt Base 1.25” Asphalt Surface

The ESALs (based on future year traffic and truck volumes) for KY 588 are calculated at 100,000. The ESAL calculation sheet is included in Appendix D. Determination or confirmation of the pavement design and calculation of the maximum ESALs the pavement could support should be made and compared to the calculated ESALs (based on traffic volumes) to confirm if the existing pavement can support the projected loadings. It can be noted that per KYTC Truck Weight Classification, KY 588 is designated as a class “A” highway with a maximum gross vehicle weight of 44,000 lbs. Construction Traffic Types Next, research was conducted to obtain the Federal Highway Administration (FHWA) vehicles classification. These categories are presented in Table 7-1.


Table 7-1: FHWA Vehicle Classification (from FHWA)

Class Type Description Typical

ESALs per Vehicle

1 Motorcycles

All two- or three-wheeled motorized vehicles. Typical vehicles in this category have saddle type seats and are steered by handle bars rather than wheels. This category includes motorcycles, motor scooters, mopeds, motor-powered bicycles, and three-wheel motorcycles. This vehicle type may be reported at the option of the State.

negligible

2 Passenger Cars

All sedans, coupes, and station wagons manufactured primarily for the purpose of carrying passengers and including those passenger cars pulling recreational or other light trailers.

negligible

3 Other Two-Axle,

Four-Tire Single Unit Vehicles

All two-axle, four tire, vehicles, other than passenger cars. Included in this classification are pickups, panels, vans, and other vehicles such as campers, motor homes, ambulances, hearses, and carryalls. Other two-axle, four-tire single unit vehicles pulling recreational or other light trailers are included in this classification.

negligible

4 Buses

All vehicles manufactured as traditional passenger-carrying buses with two axles and six tires or three or more axles. This category includes only traditional buses (including school buses) functioning as passenger-carrying vehicles. All two-axle, four-tire single unit vehicles. Modified buses should be considered to be a truck and be appropriately classified.

0.57

5 Two-Axle, Six-Tire, Single

Unit Trucks

All vehicles on a single frame including trucks, camping and recreational vehicles, motor homes, etc., having two axles and dual rear wheels.

0.26

6 Three-Axle Single Unit

Trucks

All vehicles on a single frame including trucks, camping and recreational vehicles, motor homes, etc., having three axles.

0.42


Class Type Description Typical

ESALs per Vehicle

7 Four or More Axle Single Unit

Trucks All trucks on a single frame with four or more axles. 0.42

8 Four or Less Axle Single

Trailer Trucks

All vehicles with four or less axles consisting of two units, one of which is a tractor or straight truck power unit.

0.30

9 Five-Axle Single Trailer

Trucks

All five-axle vehicles consisting of two units, one of which is a tractor or straight truck power unit.

1.20

10 Six or More Axle Single

Trailer Trucks

All vehicles with six or more axles consisting of two units, one of which is a tractor or straight truck power unit.

0.93

11 Five or Less Axle Multi-

Trailer Trucks

All vehicles with five or less axles consisting of three or more units, one of which is a tractor or straight truck power unit.

0.82

12 Six-Axle Multi-Trailer Trucks All six-axle vehicles consisting of three or more units, one of which is a tractor or straight truck power unit.

1.06

13 Seven or More Axle Multi-

Trailer Trucks

All vehicles with seven or more axles consisting of three or more units, one of which is a tractor or straight truck power unit.

1.39

Flatbed trucks that may transport construction equipment to / from the site would be classified as a Class 13. Most dump trucks will be classified as Class 7. Therefore construction equipment at the site may consist of a range of vehicles between these classes but these will be assumed to provide the upper and lower boundaries of impact. To avoid damage to the existing roadways, it is recommended that the construction traffic loading not exceed the determined design pavement ESAL loadings calculated for each location. For US 119, vehicle weight limits should not exceed 80,000 lbs to comply with legal weight limits on this route.

Mitigation Measures US 119 is not expected to have adverse impacts related to construction traffic based on the assessment of pavement design and geometric standards.


KY 588 has the potential to require mitigation measures due to additional construction traffic given the narrow lane widths and pavement design that is not at a level for a national or state truck route. Construction traffic may also affect other roadways in Letcher County. The location and intensity of these impacts can be estimated following the selection of the construction contractor(s). To minimize impacts on KY 588, and other potentially affected roadways in Letcher County, the selected construction contractor would be required to perform an assessment of the routing of construction traffic to the site. Based on this analysis, the contractor would be required to:

To the extent feasible, route construction vehicles so that the gross vehicle weight does not exceed the maximum weight limitations established by the KYTC and / or the pavement loading conditions set forth by the ESAL evaluation.

For roadways that construction traffic may exceed these limitations, damage to the roadway surface would be need to be repaired by the contractor.

For oversized vehicles and loads, maintenance of traffic plans should be developed to accommodate to maintain traffic flow during transport times. This will likely utilize flaggers to negotiate traffic flow as a result of narrow lanes.

8.0 RECOMMENDATIONS / CONCLUSION

The results presented in this document provide an overview of the anticipated traffic impacts associated with the construction of a proposed federal correctional facility in Letcher County, Kentucky. Based on the analysis conducted for this study: Both proposed sites have minimal impact on the traffic operations of the existing

nearby state routes (US 119 and KY 588). The projected LOS for traffic operations is LOS A or B which is at or better than the desired LOS B for US 119 and LOS D for KY 588.

Consideration should be given to constructing a left turn lane on US 119 and KY 588 into the site to minimize the potential for rear-end vehicle collisions. Depending on the exact site access, grade drains may need to be moved.

Construction impacts to the existing US 119 roadway are expected to be minimal (if any).

KY 588 has the potential to require mitigation measures as it is not a designated truck route and has limiting geometric features including narrow lane widths. Other roadways in Letcher County may also be affected, depending on the origin(s) of construction trips. The selected contractor for the development of this project would be required to perform an assessment of the routing of construction traffic to the site and potentially repair any surface damage caused by moving equipment as well as provide maintenance of traffic plans for moving oversized vehicles / equipment.

FINAL ENVIRONMENTAL IMPACT STATEMENT FOR ...

Documents

Transcript of FINAL ENVIRONMENTAL IMPACT STATEMENT FOR ...